Accessibility has quietly moved from a nice-to-have line in a project brief to a live legal and commercial question, and it now sits squarely on the desk of anyone who designs or builds websites for a living. Two things have changed the picture this year: the European Accessibility Act came fully into force, and long-standing UK equality law is being read against a much clearer technical yardstick than it used to be.
What’s actually changed
The European Accessibility Act (EAA) took effect on 28 June 2025 and enforcement has been building through 2026. It covers websites, apps and e-commerce checkouts, among other digital services. The UK isn’t bound by EU law on its own soil, but that doesn’t make it irrelevant here: a business is pulled into the EAA’s scope the moment it trades into the EU market — taking payments in euros, shipping to EU addresses, or running marketing aimed at EU customers all count. For a lot of UK web design and SEO agency clients who sell online across borders without thinking twice about it, that’s a wider net than they’d assume.
Separately, and more relevant to most UK-only clients, the Equality Act 2010 already requires UK service providers to make reasonable adjustments for disabled users — and a website counts as a service. No UK law names a single technical standard for the private sector, but WCAG 2.2 AA has become the working benchmark that regulators, the public sector and the courts actually look at when judging whether a site has made a genuine effort. Public bodies have been held to that exact standard since 2018 under separate accessibility regulations, so the private sector is really just catching up to where the public sector already had to be.
Who this affects — and who’s genuinely exempt
The EAA carries a microenterprise exemption: businesses with fewer than 10 employees and under €2 million in annual turnover or balance sheet total don’t have to meet its service requirements. Both conditions have to be true at once, and the exemption only applies to services, not products being sold. It’s a real carve-out for a lot of small trades clients, but it’s easy to over-read — it doesn’t touch the Equality Act’s reasonable-adjustments duty at all, which has no size threshold and applies whether or not a site sells a single thing into the EU.
In practice that means almost every client a UK web designer works with has some accessibility duty already, even if the EAA itself never applies to them. Treating accessibility as “only for big companies” or “only for EU-facing sites” is the mistake worth correcting first.
What to actually build into every new project
None of this requires reinventing how a site gets built — it means treating a known checklist as standard rather than optional:
- Genuine colour contrast between text and background, checked, not eyeballed
- Alt text on meaningful images, and empty alt attributes on purely decorative ones
- Forms with properly associated labels, clear error messages, and no reliance on colour alone to flag a mistake
- Full keyboard navigation — every interactive element reachable and usable without a mouse
- Sensible heading structure so screen reader users can actually navigate the page, not just read it top to bottom
An audit against WCAG 2.2 AA on an existing client site nearly always turns up a short, fixable list rather than a case for a full rebuild — which makes it a realistic thing to offer as a bolt-on rather than a hard sell.
Sell it as a service, not just a compliance chore
The honest framing for clients is that this was always good practice — it’s simply become good practice with a legal backbone attached. Agencies who get ahead of it have a genuine new line to offer: an accessibility audit, a fix list, and a note in writing that a site has been checked against a named standard. That’s a real, billable piece of work, and it reads to a client as competence rather than upselling. Whether an agency is based in Hackney, Kesgrave or Wetherby, the underlying standard and the underlying opportunity are exactly the same.
For the fuller detail on scope and exemptions, AbilityNet’s guide to the European Accessibility Act is a clear, UK-focused starting point.
