Retail & Consumer GoodsTechnology & Digital UK-wide

The Equality Act 2010 requires all UK businesses to make 'reasonable adjustments' to ensure disabled people can access your goods, services, and facilities. This is an anticipatory duty - you must proactively identify and remove barriers before disabled people encounter them.

The Act protects people with physical or mental impairments that have a 'substantial' and 'long-term' negative effect (12 months or more) on their ability to do normal daily activities.

What the law requires

All organisations providing goods, services, or facilities to the public must:

  • Take positive steps to remove barriers that disabled people might face
  • Not discriminate directly or indirectly against disabled people
  • Not harass or victimise disabled people
  • Make reasonable adjustments to policies, practices, and physical features

Failure to make reasonable adjustments is treated as discrimination under the Act.

Protected characteristic
Disability (physical or mental impairment lasting 12+ months with substantial impact)
Who must comply
All businesses, service providers, employers, landlords, and associations
Duty type
Anticipatory - must identify and remove barriers proactively
Cost of adjustments
Disabled people must never be charged for reasonable adjustments
Enforcement
Equality and Human Rights Commission (EHRC) and discrimination claims
Penalties
Compensation uses Vento bands (from April 2025 - Lower £1,200-£12,100, Middle £12,100-£36,400, Upper £36,400-£60,700, most exceptional can exceed £60,700). Most awards fall in middle band. Also court orders, legal costs, reputational damage

Physical premises accessibility

Your premises must be accessible to disabled people. This includes both new buildings (covered by Building Regulations) and existing premises (where you must make reasonable adjustments).

Building Regulations Part M (England)

Part M of the Building Regulations sets accessibility standards for new buildings and major alterations in England. Scotland (Building Standards), Wales (Building Regulations Wales), and Northern Ireland have separate but similar requirements.

Part M alterations. It applies to all new commercial buildings, workplaces, and public buildings in England.

Reasonable adjustments for existing premises

Even if your building predates current regulations, you must still make reasonable adjustments. What's 'reasonable' depends on:

  • The effectiveness of the adjustment in overcoming the barrier
  • The practicality of making the adjustment
  • The cost and disruption involved
  • Your organisation's size, resources, and nature
  • The availability of financial or other assistance

Examples of physical adjustments

  • Access: Installing ramps, widening doorways, adding handrails
  • Facilities: Providing accessible toilets, Changing Places facilities (for larger buildings)
  • Navigation: Clear signage, tactile indicators, good lighting, contrasting colours
  • Assistance: Providing chairs for customers who cannot stand, offering help carrying items
  • Layout: Ensuring aisles are wide enough for wheelchairs, lowering service counters

Where high-cost adjustments are required, consider whether phasing or alternative solutions might be reasonable.

Website and digital accessibility

Your website, mobile apps, and digital services must be accessible to disabled people. This applies to all UK businesses, regardless of size or sector.

Legal requirements

Under the Equality Act 2010, all UK businesses must make reasonable adjustments to ensure websites and digital services are accessible to disabled people. The recognised compliance standard is Web Content Accessibility Guidelines (WCAG) 2.2 Level AA.

Standard
WCAG 2.2 Level AA (became legal standard October 2023, public sector monitoring from October 2024)
Who it applies to
All UK businesses with websites or apps (private and public sector)
Assistive technologies
Must work with screen readers, screen magnifiers, speech recognition, keyboard-only navigation
Key requirements
Text alternatives for images, keyboard navigation, 4.5:1 colour contrast minimum, clear forms and error messages
Business impact
£274 billion Purple Pound annual spending power (DWP 2020 estimate) - £17.1 billion lost annually from inaccessible websites (Click-Away Pound Survey 2019)

European Accessibility Act (EAA) impact

The European Accessibility Act came into force in the EU on 28 June 2025. Even if your business is UK-based, if you sell into the EU and have more than 10 staff and over €2 million (£1.7 million) in annual turnover, you must comply with EAA requirements.

Current EAA uses WCAG 2.1 Level AA via EN 301 549, but organizations should consider WCAG 2.2 as future updates will align with it.

WCAG principles

The four core principles of web accessibility:

  • Perceivable: Users must be able to perceive content using their senses (sight, hearing, touch)
  • Operable: Users must be able to control UI elements and navigate the site
  • Understandable: Content should be simple, direct, and predictable
  • Robust: Websites must be compatible with current and future assistive technologies

Common accessibility issues

  • Images without alternative text descriptions
  • Poor colour contrast between text and background
  • Forms without clear labels or helpful error messages
  • Navigation that doesn't work with keyboard alone
  • Auto-playing videos without controls
  • PDFs and documents that aren't screen-reader accessible
  • Inconsistent navigation and page structure
  1. Audit your website

    Use automated tools (WAVE, axe DevTools) and manual testing with screen readers. Better still, engage disabled users for real-world testing.

  2. Fix critical issues first

    Prioritise navigation, forms, and core user journeys. Ensure keyboard accessibility and proper heading structure.

  3. Train your team

    Ensure developers, designers, and content creators understand WCAG requirements and how to implement them.

  4. Test with assistive technologies

    Use screen readers (NVDA, JAWS, VoiceOver), screen magnifiers, and keyboard-only navigation to experience your site as disabled users do.

  5. Consider an accessibility statement

    While not legally required for private sector, publishing a statement demonstrates commitment and provides contact routes for feedback.

TECHNOLOGY & DIGITAL Requirement

Software and app accessibility requirements

If you develop software, mobile apps, or digital products, accessibility requirements extend beyond websites. The Equality Act's reasonable adjustments duty applies to all digital products and services.

What you must do

  • Follow WCAG 2.2 Level AA for web-based products
  • For mobile apps, follow platform-specific guidelines (iOS Accessibility Guidelines, Android Accessibility Guidelines) plus WCAG
  • Ensure compatibility with screen readers, voice control, and switch access
  • Provide customisation options (text size, colour schemes, reduced motion)
  • Test with disabled users throughout development

Native app requirements

  • iOS: Use UIAccessibility APIs, support VoiceOver, provide meaningful labels for all interactive elements
  • Android: Use accessibility framework, support TalkBack, ensure touch targets are 48x48dp minimum
  • Cross-platform: Test on multiple devices and with different assistive technologies

Documentation and support

  • Provide accessible user documentation (text alternatives for images, proper headings, clear language)
  • Ensure help systems work with assistive technologies
  • Offer accessible customer support channels (not just phone-only)
  • Publish accessibility conformance information (VPAT or ACR for enterprise software)
Who this applies to: All UK businesses developing software, mobile apps, or digital products for public use, whether commercial or free. Particularly relevant for SaaS providers, app developers, and enterprise software companies.
Enforcement:

Enforced through the Equality Act 2010 by the Equality and Human Rights Commission. Disabled users can file discrimination claims if digital products create accessibility barriers.

For EU markets, EAA compliance is mandatory from June 2025 for businesses meeting the size thresholds.

Service provision and auxiliary aids

You must provide auxiliary aids and services to help disabled people access your services. This includes providing information in alternative formats and making your service delivery accessible.

Information in alternative formats

The Equality Act 2010 states that it will always be reasonable to take steps to ensure information is provided in an accessible format. Examples include:

  • Visual impairments: Large print, braille, audio formats, screen-reader compatible PDFs
  • Hearing impairments: British Sign Language (BSL) interpretation, written summaries of verbal information, induction loops, subtitles for videos
  • Cognitive impairments: Easy Read formats, simplified language, visual aids

Communication support

  • BSL interpreters for important meetings or appointments
  • Lip speakers for people with partial hearing
  • Note takers for people who cannot write
  • Accessible booking and appointment systems

Staff training

All customer-facing staff should understand:

  • Their legal obligations under the Equality Act
  • How to communicate effectively with disabled people
  • What adjustments your business can offer
  • How to respond to requests for reasonable adjustments
  • Disability awareness and etiquette (e.g., asking before helping, speaking directly to the disabled person not their companion)

Employment and Access to Work

As an employer, you must make reasonable adjustments for disabled employees and job applicants. The Access to Work scheme can help fund adjustments.

Reasonable adjustments for employees

You must make adjustments to:

  • Workplace policies: Flexible working hours, modified targets, adjusted disciplinary procedures
  • Physical features: Accessible workstations, parking spaces, toilets
  • Equipment: Specialist software, ergonomic furniture, assistive technology
  • Work arrangements: Modified duties, phased return to work, additional supervision or support

These adjustments apply to employees, trainees, apprentices, contract workers, and business partners. You cannot make disabled workers pay for reasonable adjustments.

Access to Work scheme
Government grant providing practical and financial support for disabled people in work
What it covers
Special equipment, software, travel costs (if can't use public transport), support workers, job coaching
Eligibility
Must have disability or health condition affecting work, be employed or self-employed above lower earnings limit (£6,500 per year for 2025/26)
Cost sharing
Employers pay 100% up to threshold (£0 for <50 staff, £500 for 50-249 staff) plus 20% of costs between threshold and £10,000. Access to Work pays up to 80% between threshold and £10,000. AtW normally pays any balance over £10,000
Does not cover
Reasonable adjustments (employer's legal duty)
Application
Apply online or phone 0800 121 7479, can apply up to 6 weeks before starting job with written offer
Current delays (2025)
Average decision time 84.6 days (up from 46 days in 2024)
  1. Discuss needs with employee

    Have an open conversation about what adjustments would help. Don't assume - ask the individual what they need.

  2. Explore Access to Work

    Check if Access to Work can fund adjustments. Point employees to the scheme and support their application.

  3. Implement adjustments promptly

    Don't wait for Access to Work approval to make reasonable adjustments. Many cost little or nothing.

  4. Review regularly

    Needs can change over time. Review adjustments periodically and after any changes to role or condition.

RETAIL & CONSUMER GOODS Requirement

Retail accessibility requirements

Retail businesses face specific accessibility obligations under the Equality Act 2010 to ensure disabled customers can access shops and services.

Physical store accessibility

  • Entrance access: Level or ramped access where possible, doors wide enough for wheelchairs (minimum 850mm clear opening for new buildings), accessible door handles
  • Navigation: Aisles wide enough for wheelchairs (minimum 1200mm recommended), clear floor space, good lighting with minimal glare
  • Fixtures and fittings: Lowered sections of service counters, accessible shelving where possible, seating for customers who cannot stand
  • Facilities: Accessible toilets if you provide customer toilets, accessible changing rooms in clothing stores
  • Assistance: Offer to help carry items, read labels, or reach products for customers who need it

Point of sale accessibility

  • At least one till with lowered counter section for wheelchair users
  • Chip and PIN devices positioned for seated customers
  • Alternative payment methods for customers who cannot use keypads
  • Receipts and information available in alternative formats on request

Information and signage

  • Clear, well-lit signage with good colour contrast
  • Large print price labels and product information
  • Accessible website for click-and-collect and online ordering
  • Staff trained to provide information in alternative formats

Business impact

Research by We Are Purple found:

  • £249 billion: Annual Purple Pound spending power of disabled people and families
  • 75% of disabled people have walked away from a business due to poor accessibility
  • 1 in 5 shops exclude wheelchair users
  • Only a tiny proportion of shops have hearing loops
Who this applies to: All retail businesses providing goods or services to the public, from sole traders to large chains. Obligations apply whether you operate from permanent premises, pop-up shops, or market stalls.
Enforcement:

Enforced by the Equality and Human Rights Commission through the Equality Act 2010. Disabled customers can file discrimination claims. Building Regulations enforcement by local authorities can require remedial work up to 10 years after completion.

Consequences include compensation payments, court orders requiring improvements, legal costs, and reputational damage.

FOOD, DRINK & HOSPITALITY Requirement

Hospitality accessibility requirements

Hospitality businesses (restaurants, pubs, cafes, hotels, entertainment venues) have specific accessibility obligations beyond general retail requirements.

Legal framework

  • Equality Act 2010, Section 20: Reasonable adjustments duty for service providers
  • Building Regulations Part M: New buildings must have reasonable provisions for access and use by disabled people
  • Anticipatory duty: Must proactively identify and remove barriers before disabled customers encounter them

Physical accessibility requirements

  • Entry: Step-free access as far as possible - ramps with shallow gradients where entrance is on different level from boundary or car park
  • Circulation: Wide enough corridors and doorways for wheelchair users, clear routes to all customer areas
  • Seating: Accessible table options (not booth-only), space for wheelchair users to remain in their wheelchairs
  • Toilets: Accessible toilets where toilets are provided for customers - in principle should be accessible to everybody including wheelchair users
  • Changing Places: Larger venues should provide Changing Places facilities (adult-sized changing benches, hoists, etc.)

Service delivery adjustments

  • Menus: Large print menus, braille menus, picture menus, digital menus compatible with screen readers
  • Communication: Staff trained in disability awareness, ability to communicate dietary requirements clearly, BSL interpretation or written communication for deaf customers
  • Assistance: Help with carrying trays, reading menus, accessing facilities
  • Allergen information: Available in accessible formats

Current state of accessibility

Research findings highlight significant gaps:

  • 80% of respondents cited inaccessibility in entertainment and hospitality sector (highest of all sectors)
  • 40% of restaurants have no accessible toilet
  • 1 in 5 dining establishments do not cater for visual impairments
  • Only a tiny proportion have hearing loops

Financial impact of poor accessibility

  • Restaurants, pubs, and clubs lose an estimated £163 million Purple Pounds per month
  • Annual Purple Pound spending power £249 billion
  • 75% of disabled people have walked away from a UK business because of poor accessibility or customer service
Who this applies to: All hospitality businesses serving the public, including restaurants, cafes, pubs, bars, hotels, B&Bs, entertainment venues, and event spaces. Applies regardless of business size or whether premises are owned or leased.
Enforcement:

Enforced under the Equality Act 2010 by the Equality and Human Rights Commission. Building Regulations enforced by local authorities, which can require remedial work up to 10 years after completion (changed from 12 months in October 2023).

Consequences include discrimination claims with compensation using Vento bands (from April 2025: Lower £1,200-£12,100, Middle £12,100-£36,400, Upper £36,400-£60,700, most awards fall in middle band), court orders requiring improvements, enforcement notices, and reputational damage.

Access audits and compliance

Consider conducting an accessibility audit to identify barriers and prioritise improvements.

What an access audit covers

  • Physical access: Routes, entrances, doors, corridors, stairs, lifts
  • Facilities: Toilets, parking, seating, service counters
  • Environment: Lighting, acoustics, signage, wayfinding
  • Communication: Information provision, staff awareness, booking systems
  • Policies: Service delivery procedures, complaints handling, emergency evacuation

Who can conduct audits

  • In-house: Train staff to conduct basic audits using checklists
  • User testing: Engage disabled people to test your premises and services
  • Professional: Hire access consultants or audit services for comprehensive assessments
  1. Conduct an access audit

    Systematically review your premises, website, and service delivery for accessibility barriers. Consider engaging disabled people as consultants.

  2. Develop an action plan

    Prioritise barriers based on impact and feasibility. Plan phased improvements if large-scale work is needed.

  3. Train all staff

    Ensure everyone understands legal obligations, available adjustments, and how to communicate with disabled customers and colleagues.

  4. Publicise your commitment

    Make it clear you welcome disabled customers. Display information about available adjustments and how to request them.

  5. Seek feedback

    Ask disabled customers and employees about barriers and how to improve. Act on feedback received.

  6. Review regularly

    Accessibility is ongoing. Review annually and when making changes to premises, services, or digital platforms.