WCAG Law: Understanding the Updated Version in a UK context
WCAG stands for Web Content Accessibility Guidelines. It is not a law itself but rather a set of guidelines published by the World Wide Web Consortium (W3C), an international community that develops open standards to ensure the long-term growth of the Web.
These guidelines are designed to make web content more accessible to people with disabilities. While WCAG itself is not a law, many countries and regions have incorporated WCAG standards into their accessibility laws and regulations.
For example, they are referenced in the UK's Equality Act 2010, which requires organisations to make reasonable adjustments to ensure that disabled people are not at a substantial disadvantage compared to non-disabled people.
The UK government has also adopted the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. These regulations require public sector bodies, including government agencies, local authorities and certain other organisations, to ensure that their websites and mobile applications meet certain accessibility standards.
In June 2025, the EU will pass its new European Accessibility Act (EAA) which will include Digital Accessibility (informed by WCAG). It will apply to all countries in the EU, and international organisations that do business in the EU. Therefore, it applies to any organisations in the UK doing business in the EU.
WCAG and how it's developed
This article outlines the key differences in versions of WCAG from the first iteration in 1999 (WCAG 1.0) to the most recent version (WCAG 2.2) published in October 2023.
*I've included other sources to clarify the differences as much as possible.
WCAG 1.0 (1999) focused heavily on the techniques for accomplishing accessibility, especially as related to HTML.
WCAG 2.0 (2008) was based on four main guiding principles of accessibility known by the acronym POUR: perceivable, operable, understandable, and robust.
WCAG 2.1 (September, 2023) - There are seventeen new criteria that differentiate the WCAG 2.0 and the WCAG 2.1. But the biggest difference is the advanced considerations for mobile users. WCAG 2.1 has a larger occurrence on mobile usage and the preferences of those with low vision and those with cognitive disabilities. (Source: Usablenet)
WCAG 2.2 (October 2023) extends WCAG 2.1. WCAG 2.2 was initiated with the goal to continue the work of WCAG 2.1: Improving accessibility guidance for three major groups: users with cognitive or learning disabilities, users with low vision, and users with disabilities on mobile devices.
The 2.0 and 2.1 success criteria are essentially the same in 2.2, with one exception: 4.1.1 which concerns Parsing.
Parsing was included in WCAG 2.0 to ensure that browsers and assistive technologies could accurately parse markup and content. Since then, specifications (such as HTML) and browsers have improved how they handle parsing errors. Also, previously assistive technology did their own markup parsing. Now they rely on the browser. With today’s technology, accessibility issues that would have failed 4.1.1, will fail other criteria, such as Info and Relationships (SC 1.3.1) or Name, Role, Value (SC 4.1.2). Therefore 4.1.1 is no longer needed for accessibility (Source: w3).
SOURCE: CUNY Library
Levels of WCAG
Level A and AA are considered conformance and what you must have for your application/website to be considered accessible, i.e. compliant to the laws. These two levels are what organisations target for in most cases, but there is also Level AAA, a higher standard, generally considered best practice.
SOURCE: Applause
Why does any organisation need to comply with WCAG?
If your organisation has a website, it should be accessible to disabled users. When a website or online service is not accessible, it’s considered discrimination.
Anyone who owns a website should try to understand WCAG.
WCAG and the Equality Act 2010
The Equality Act 2010 states that organisations must make ‘reasonable adjustments’ to make sure their services are accessible. This is so that disabled people are not excluded because of their impairment.
The Equality Act considers both physical and digital access to services. Including websites, apps and documents like PDFs, too.
European Union (EU) laws
Before the UK left The EU in January 2020, the UK government had to follow EU web accessibility laws.
This included The European Union (EU) Directive on the Accessibility of Websites and Mobile Applications. The law came into effect in December 2016.
The UK gov created regulations for public sector websites to help us follow this EU law:
The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 . This is sometimes shortened to PSBAR.
As far as I can see, the UK is still enforcing the PSBAR despite us not being a part of the EU anymore.
SOURCE: Scope for Business
The link between the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 and WCAG
The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 adopts the latest version of the W3C's Web Content Accessibility Guidelines (WCAG). That means for public sector websites and mobile applications, the technical requirements are still WCAG conformance.
Who has to meet the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018?
All public sector bodies in the UK have to meet the 2018 requirements unless they are exempt.
Public sector bodies include:
central government and local government organisations
some charities and other non-government organisations
Accessibility regulations for public sector bodies
The accessibility regulations came into force for public sector bodies on 23 September 2018. They say you must make your website or mobile app more accessible by making it 'perceivable, operable, understandable and robust' (referencing WCAG). You need to include and update an accessibility statement on your website.
How the accessibility regulations are monitored and enforced
The Government Digital Service (GDS) monitors public sector bodies’ compliance on behalf of the Minister for the Cabinet Office. GDS does this by examining a sample of public sector websites and mobile apps every year. GDS can ask for information and request access to intranets, extranets, apps or any public sector website.
SOURCE: gov.uk
The European Accessibility Act (EAA)
The European Accessibility Act is due to be passed on June 28, 2025. It will apply to all countries in the EU and international organisations that do business in the EU.
Preparing for the EAA
The impending legislation underscores the need for industries to adapt and comply.
Many companies have yet to achieve accessibility readiness and may face penalties if they fail to comply.
SOURCE: The Drum
What will the EAA 2025 entail?
The key advancement in the EAA 2025 will be Digital Accessibility. The focus is on adhering to the Web Content Accessibility Guidelines (WCAG), guiding for creating accessible digital content.
SOURCE: Hurix Digital
What happens if organisations don't comply with EAA 2025?
The competent authorities can investigate complaints about accessibility and take enforcement action against businesses and public sector bodies that do not comply with the EAA requirements.
SOURCE: Silktide
What does this mean for UK businesses and organisations?
While currently, all UK website owners must make their sites accessible due to the Equality Act 2010, only public sectors are required by law to follow WCAG in line with the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018.
However, as the EAA 2025 will include Digital Accessibility, all UK organisations doing business in the EU will be required by EU law to comply.