Website design company guide to UK public sector accessibility

What to take away

The Public Sector Bodies Accessibility Regulations 2018 and who they cover

The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 apply across the United Kingdom. They came into force for new public sector websites in September 2018, for existing websites in September 2019 and for mobile apps in June 2021.

The rules require public sector bodies to make their websites and mobile applications accessible to disabled people. The technical benchmark is WCAG 2.2 level AA, applied to the whole site and app, not a sample of pages. The regulations sit alongside the Equality Act 2010 in England, Scotland and Wales, and the Disability Discrimination Act 1995 in Northern Ireland.

Covered bodies include central government departments, local authorities, NHS trusts, police and fire services, and arm's length bodies. State schools, further and higher education institutions and many bodies mostly funded by public money are also in scope. The Department for Work and Pensions, HM Revenue & Customs, the Information Commissioner's Office and Companies House all publish statements as public authorities.

Some bodies are exempt. The main exemptions are the armed forces, some public service broadcasters, and non government organisations that do not provide services essential to the public or specifically aimed at disabled people. Schools and nurseries are exempt for content on internal networks, but not for their public websites.

A short list of organisations is exempt, including certain non-governmental organisations and some broadcasters, but GOV.UK lists no exemption for small organisations as such, so this is a narrow gate. Most councils, trusts and colleges do not qualify. A website design company should not assume a client is exempt without checking the test in writing.

Who actually carries the duty? The public sector body does. Procurement can push the work to an agency, but the legal obligation stays with the body. That split matters when monitoring finds a fault and the supplier has already been paid.

What an accessibility statement must contain and where it is published

An accessibility statement is a public document, not a private audit. It must be published on the website, and GOV.UK treats a link from every page, usually in the footer, as good practice. There is no single required URL, but the statement must be easy to find and not buried behind a contact form.

Use the Government Digital Service sample accessibility statement in its GOV.UK guidance on making a website or mobile app accessible and publishing a statement. Adapt the model to identify inaccessible content and explain why it fails, describe accessible alternatives, set out how users can report problems or complain to the enforcement authority, and record the testing method and statement date.

Where a body has an app, the statement must cover it too. Where a site relies on an external platform, for example a booking system or a payment provider, the statement should say who is responsible for that part.

A weak statement names no failures. A useful one names the specific content types that fail, the WCAG criteria involved and the date a fix is expected. Vague phrases such as "we are committed to accessibility" carry no weight with a monitoring team or a complainant.

The statement must be reviewed whenever the site changes materially, and at least once a year. A redesign, a new content management system or a new third party widget all trigger a review.

This is where a website design company can add real value: drafting the statement, keeping a change log and handing over a template the client can maintain.

One practical trap is the statement that is technically present but not accessible itself. If the statement uses an image of text, poor contrast or a PDF only version, it fails the same test it describes.

Monitoring by the Government Digital Service and the sampling approach

The Government Digital Service, part of the Cabinet Office, owns public sector accessibility monitoring. Its role is set out on its Government Digital Service - GOV.UK page, which also explains how the monitoring team works with departments and regulators.

Monitoring is not a full audit of every site. The team samples. It selects a mix of central government, local government, NHS, education and other bodies each year, then tests a defined set of pages and user journeys. The sample usually covers the homepage, a form, a content page, a policy or publication page and, where relevant, an app.

For a manual sample, test the homepage, a content page, a key form and a policy or publication page, including any PDF users need. Tools such as axe DevTools or WAVE can flag some issues, but also test with a keyboard and a screen reader such as NVDA or VoiceOver. Check form labels and errors, focus order and visibility, contrast and reflow, and record the browser, assistive technology and results.

The test method follows WCAG 2.2 AA and combines automated tools with manual checks. Automated tools catch perhaps a third of issues; the rest need keyboard testing, screen reader testing and judgement. Monitoring reports are shared with the body, which is asked to respond with a plan.

If a body does not respond or does not fix serious failures, the monitoring team can escalate. In England, Scotland and Wales the relevant regulator is the Equality and Human Rights Commission; in Northern Ireland it is the Equality Commission for Northern Ireland. A user can report a problem through the statement's feedback route and, if it is not resolved, complain to the relevant enforcement authority. The Equality and Human Rights Commission has investigation and enforcement powers under the Equality Act 2006, including investigations and unlawful act notices; the Equality Commission for Northern Ireland has investigation and enforcement functions under the Disability Discrimination Act 1995 (Northern Ireland). The Cabinet Office can also write to the responsible minister.

Monitoring results feed into wider public sector reporting. For suppliers, the practical point is that a site can pass at launch and fail two years later. Content, plugins and third party embeds drift. That is why a website design company should offer a monitoring readiness review, not just a launch audit.

Where public sector websites and apps still fall short

Failures cluster in predictable places. The template is often fine; the content and the add ons are not. The most common problems found in monitoring and in complaints are listed below.

Common failures to check include:

Mobile apps fail in similar ways: unlabelled buttons, gesture only navigation, poor screen reader order and no support for text resizing. Apps are covered by the same regulations and are monitored.

For apps, check that buttons expose their name, role and value to assistive technology (WCAG 4.1.2, Name, Role, Value), and that gesture-based interactions have an alternative where required (2.5.1, Pointer Gestures).

There is also a governance gap. Many bodies buy a compliant build, then let the accessibility statement go stale. Others treat accessibility as a project rather than a service. A website design company that offers a retainer with quarterly testing and editor training closes that gap; one that only ships a build does not.

Procurement practice matters here too. Public buyers are expected to weigh social value and delivery risk, as set out in Procurement in the national interest - GOV.UK, and accessibility evidence is increasingly part of that assessment.

What a website design company must evidence before handover

Before handover, a website design company should be able to show evidence, not assurances. The client is the duty holder, so the agency's job is to make that duty easy to discharge. The following checklist is a reasonable minimum for any public sector build.

A practical handover evidence checklist includes:

An example that has been worked through illustrates how this appears in practice. A district council in the West Midlands relaunches its site with a new design system. The agency tests the top twenty tasks, finds that the bin collection form fails on error messaging and that the planning portal is a third party product.

It fixes the form, flags the portal as a known failure in the statement with a target date, trains six editors and schedules a re test after three months. Monitoring later samples the site and finds the statement accurate, so no escalation follows.

That is the standard to aim for. A site does not need to be perfect; it needs to be honest, tested and improving. Buyers should treat accessibility as a separate gate in supplier selection, as set out in the agency quality checklist, rather than a line item inside a general quality score.

Agencies that manage releases as controlled events are better placed here, because each release carries a test record. Public sector clients should also know what to verify at every gate before signing, and can use the UK agency accessibility guidance when checking supplier claims.

Remediation routes, timescales and agency contract implications

Remediation depends on what failed. Content fixes are fast: alt text, headings, link text and contrast can be corrected in days. Template and component fixes take weeks, because they touch the design system and need regression testing. Legacy systems, PDF archives and third party platforms take months and sometimes need a replacement decision.

A realistic sequence looks like this.

A practical remediation sequence is:

Contract terms matter. Public sector clients should ask for accessibility acceptance criteria in the statement of work, a warranty period long enough to catch post launch drift, and a clear right to re test. They should also agree who pays for fixes after handover and how disputes are handled.

The statement of work and contract should make the following points explicit:

Consumer protection and fair contract terms guidance is relevant to how these contracts are drafted and enforced, including the material published in the Consumer protection guidance for businesses - GOV.UK collection.

Public bodies are not consumers in the ordinary sense, but the principles of clear terms and no hidden charges still apply to the frameworks and call off contracts they use.

Timescales should be written into the plan, not left to goodwill. A common pattern is a thirty day fix window for blockers, ninety days for serious issues and a named date for the rest.

Where a third party is the blocker, the client needs a fallback, such as an accessible alternative route or a phone number, published in the statement.

Finally, budget for the ongoing work. Accessibility is a service cost, not a one off project cost. A modest annual retainer for testing, statement updates and editor training is cheaper than an enforcement case, a rebuild or a procurement reset.

Common questions