Web Accessibility Training

Introduction to UK web accessibility legislation for public sector websites

International legislation

There isn't an internationally agreed legal standard for web accessibility; different jurisdictions refer to different guidelines due to cultural and legal variance as well as regional requirements.

It's important to bear this in mind if you read other websites that discuss web accessibility requirements, as they may not be referencing the current legal situation in the UK.

You may also read elsewhere that the Web Content Accessibility Guidelines (WCAG) are the internationally agreed standard. This isn't entirely accurate; WCAG is internationally recognised, but whether and how it is implemented varies by region.

UK legislation

Regulations

In the UK, there are three pieces of legislation, with web accessibility relevance, applicable to University websites:

An organisation that is subject to the first two Acts is required to make reasonable adjustments for individuals with disabilities, so that those individuals are not disadvantaged. For online content, this means providing material in alternative formats, such as braille, on request, where complying with that request constitutes a reasonable adjustment.

PSBAR, on the other hand, requires insitutions to proactively edit their online content to make it accessible. It references selected Web Content Accessibility Guidelines (WCAG) as criteria to assess compliance, and this compliance is audited by the UK Government.

Exemptions

SENDA and the Equality Act 2010 have a broader scope than PSBAR. Some web content is exempt from the requirement to comply with PSBAR, but in those cases, SENDA and the Equality Act 2010 will still apply.

So, to be clear: even if an element of web content is exempt from PSBAR, the requirement to provide an alternative format on request will still apply, if provision of that alternative constitutes a reasonable adjustment.

It's important to be aware of this so that anyone making an alternative format request is not incorrectly told that the content is exempt from the requirement to supply that alternative, simply because it complies with, or is exempt from, PSBAR – this is not the case.

This scenario is discussed further, under legislative exemptions. Exemptions for mobile apps are mentioned separately, under mobile app roles.

SensusAccess

SensusAccess (link opens in new window) is a tool that provides the facility for students, staff and alumni to convert digital content into other formats.

However, SensusAccess does not make content PSBAR compliant. So, if the content is not compliant prior to SensusAccess conversion, it won't be compliant afterwards. It's also possible that PSBAR-compliant content will no longer be compliant after it's been converted using SensusAccess.

In short, SensusAccess is useful for providing alternative versions of content under the terms of SENDA and the Equality Act 2010, but if the converted content is to be used online, it may need to be PSBAR-compliant (see exemptions to check). If it does need to be PSBAR-compliant, then it will need checking and possibly revision to make it so, after being converted. In some cases, it may be easier to create the alternative format from the beginning, implementing compliance as you develop it, rather than using SensusAccess for this.

Web Content Accessibility Guidelines (WCAG)

The WCAG are a set of recommendations, produced by the World Wide Web Consortium (W3C), which was founded in 1994 by Tim Berners-Lee, the inventor of the web.

The most recent edition of the WCAG is WCAG 2.2 (external website – opens in new window), which was published on 5th October 2023.

WCAG 2.2 replaced WCAG 2.1 as PSBAR assessment criteria on 1st October 2024. This is important because:
  • When reading other websites you may see reference to 2.0 or 2.1 as the standard, depending on when the site was last updated and which international region it refers to.
  • If you use a web accessibility scanner, you may be presented with options where you will need to select the correct standard. Some older scanners may not have an option for 2.2 if they haven't been updated.
  • You may also simply see '2', which tends to mean 2.0, as this was used before 2.1 was published.
The correct standard for our websites is 2.2.

WCAG criteria are all ranked at one of three levels: A, AA or AAA. Level A is the lowest standard and AAA is the highest.

UK regulations require all public sector websites, and public sector mobile apps that are used by the general public, to comply with WCAG 2.2 to Level AA. This means that web content within scope must be compliant with all criteria ranked at A or AA, and any criteria not met by that content must be listed in an accessibility statement.

A note on WCAG implementation for those working with mobile apps

This website will look at WCAG as it's applied to websites. WCAG references HTML (web code) which means that a slightly different approach is required for those working with mobile apps, as they use other types of code – processes and procedures for mobile apps are therefore not covered on this website.

A note on WCAG implementation for web editors

WCAG 2.2 is extensive and quite technical in nature, and we do not expect editors using University-supported web editing platforms, such as T4 and ELE, to follow it in its original form.

Instead, editors using these platforms should follow the practical training provided for them, which will break down the WCAG requirements into rules and guidelines to follow when creating and editing content. The legal background has been included here only so that you can understand the importance of this. 

Future developments

WCAG is periodically updated – around once every 5 years – to keep pace with new code, new technologies, new understandings about accessibility, and new solutions for accessibility barriers. Web accessibility training is, therefore, an ongong process.

WCAG 3.0 is already in development, and is thought likely to include new compliance criteria for virtual reality, augmented reality and streaming.

Audits

On behalf of the Minister for the Cabinet Office, the Government Digital Service – which is part of the Department for Science, Innovation and Technology – conducts unscheduled audits on public sector web content to ensure that it meets the regulatory standard. Audit notifications are issued directly from the Cabinet Office.

The UK Government website has further information on its monitoring methodology (external website – opens in new window).

European legislation

The European Accessibility Act (EAA) will be implemented by members of the EU from 28th June 2025. While this directive doesn't apply directly to the UK, it nevertheless requires providers of commercial digital products and services to meet its standards when those products or services are being sold or distributed in the EU. The standard set is WCAG 2.1 (note, not 2.2 as in the UK's PSBAR). As 2.2 encompasses 2.1, content that is compliant with 2.2 will automatically be compliant with 2.1.

A key difference between EAA and PSBAR is that each member state enforces EAA through its own legislation. This means that each member independently determines the format in which it will accept the accessibility statement (sometimes called Declaration of Conformity or Declaration of Accessibility), how it will enforce compliance, and what the penalties for non-compliance will be.