Accessible Websites for Charities: What the Law Actually Requires

Key Takeaways

• The Equality Act 2010 applies to every UK charity as a service provider — an inaccessible website is a legal liability regardless of your size or budget.
• The Public Sector Bodies Accessibility Regulations (PSBAR) apply to public sector bodies, not to most independent charities — but WCAG 2.1 Level AA is still the practical benchmark for Equality Act compliance.
• Approximately 14.6 million people in the UK have a disability; an inaccessible site blocks them from your services, your fundraising, and your content (Scope, Disability Facts and Figures, 2024).
• The most common failures — low contrast text and missing alt text — affect 81% and 54.5% of websites respectively, and can often be fixed in hours (WebAIM Million, 2024).
• Free automated tools — WAVE, Lighthouse, axe — find the majority of issues in under an hour at no cost.

Most charity websites have accessibility problems. In 2024, WebAIM analysed one million home pages and found that 95.9% had at least one detectable WCAG 2.1 failure (WebAIM Million, 2024). Charity websites are not an exception to that pattern.

The question isn't whether your site has issues — it almost certainly does. The question is what the law actually requires, which regulations apply to you specifically, and what a realistic remediation path looks like. The answers are more accessible than most guides make them sound.

---

Does UK law require charities to have accessible websites?

Yes. Every UK charity that provides services to the public has a legal obligation to make reasonable adjustments for disabled service users under the Equality Act 2010, and that obligation covers your website.

Section 29 of the Act prohibits service providers from putting disabled people at a substantial disadvantage compared to non-disabled people (Equality Act 2010, Section 29). A website that a screen reader user cannot navigate, or that someone with low vision cannot read because of insufficient colour contrast, is a barrier under that definition.

The Act does not prescribe a technical standard — it does not mention WCAG or any specific framework. What it requires is that you take anticipatory, proactive steps to remove barriers. The "reasonable" threshold scales with your organisation's size and resources: a community charity with three volunteers is held to a different standard than a national organisation with a £5 million turnover. But "reasonable" does not mean "optional." Taking no action — particularly when free tools identify serious issues in under an hour — is unlikely to satisfy the duty.

Approximately 14.6 million people in the UK have a disability, representing around 22% of the population (Scope, 2024). Many use assistive technology: screen readers, keyboard-only navigation, voice input, high-contrast modes, zoom magnification. A website that does not work with those tools is effectively closed to a significant share of your donors, volunteers, service users, and potential supporters.

---

Do the Public Sector Accessibility Regulations apply to charities?

Only if your charity is classified as a public sector body. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 — PSBAR — create more specific, enforceable obligations than the Equality Act: WCAG 2.1 Level AA compliance, a published accessibility statement, and a monitored process for accessibility complaints (PSBAR 2018).

PSBAR applies to public sector bodies — central government departments, local authorities, NHS trusts, and similar organisations. Most small independent charities are not public sector bodies. A food bank, a local hospice, or a community arts charity is not automatically in scope.

Where it gets nuanced: charities delivering publicly contracted services — social care, housing support, employment programmes — may be classified as public sector bodies depending on their funding structure and the extent of delegated public functions. If your organisation delivers services under a local authority or NHS contract, check with your commissioner or legal advisor before concluding PSBAR does not apply.

The Cabinet Office guidance is available at gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps and is worth reading even if you are unsure of your status.

Even where PSBAR does not technically apply, treat its requirements as your working standard. WCAG 2.1 AA is what courts and tribunals use as a reference point in Equality Act claims, and major funders — including the National Lottery Community Fund — are increasingly referencing WCAG compliance in their grant conditions. Compliance with WCAG 2.1 AA is the defensible position regardless of your legal classification.

---

What does WCAG 2.1 AA mean in practice?

WCAG — the Web Content Accessibility Guidelines — is published by the W3C (World Wide Web Consortium). Version 2.1, published June 2018, is the current legal minimum in the UK (W3C, WCAG 2.1). Version 2.2 (October 2023) adds nine new success criteria — larger touch targets, more flexible authentication, and consistent help mechanisms — and is worth targeting when you next rebuild or redesign (W3C, WCAG 2.2).

WCAG 2.1 AA has 50 success criteria across four principles, summarised as POUR:

Perceivable — can everyone perceive your content? Text must meet a minimum contrast ratio of 4.5:1 against its background. Images must have descriptive alt text. Videos need captions. You cannot rely on colour alone to convey meaning.

Operable — can everyone operate your website? Every interactive element must work with a keyboard alone — no mouse required. Users must have enough time to complete forms. Nothing may flash more than three times per second (seizure risk). Navigation must include a way to skip past repetitive content.

Understandable — is the content clear and predictable? The page language must be declared in the HTML. Error messages must identify what went wrong and how to fix it. Form fields must have visible labels linked programmatically to their inputs.

Robust — does the site work with assistive technology? HTML must be valid and well-structured. Interactive elements must have accessible names. The site must function with current and future assistive tools.

The chart below shows where most websites currently fail — and the pattern is strikingly concentrated in a small number of repeatable mistakes.

---

What are the most common failures, and how do you fix them?

Low contrast text (81.0% of pages) is the single most widespread failure. WCAG 2.1 AA requires a contrast ratio of at least 4.5:1 between normal text and its background, or 3:1 for large text (18pt+ or 14pt bold). Common offenders: light grey on white, brand-coloured text on pale backgrounds, and text overlaid on photography. Check every colour combination in your website against the free Colour Contrast Checker at colourcontrast.cc. Most sites can be fully assessed in under thirty minutes.

Missing alt text (54.5% of pages) makes images invisible to screen reader users. Every image that conveys information needs an alt attribute describing what it shows. Purely decorative images should carry an empty alt attribute (alt="") so screen readers skip them. The failure is rarely intentional — it usually results from a CMS defaulting to blank alt fields and staff who have never been shown how to fill them in.

Missing form labels (48.6% of pages) make donation forms, sign-up forms, and contact forms unusable for keyboard and screen reader users. A sighted user sees the label beside a form field and understands its purpose. A screen reader user hears only "text field" — no context. Linking each field to a <label> element, or adding an aria-label attribute, fixes this in minutes per form.

Empty links (44.6% of pages) — links labelled "click here," "read more," or carrying an image without alt text — give screen reader users navigating by link list no information about where the link leads. Replace vague link text with descriptive text: "Read our 2024 annual report" is navigable; "click here" is not.

These four fixes address the majority of access barriers on most charity websites. None requires a redesign or a full technical rebuild.

---

How do you test your website for accessibility?

Automated tools find approximately 30–40% of WCAG failures. The remainder require human judgement. But that 30–40% includes most of the high-frequency, high-impact issues listed above. Starting with automated tools is the right first step, and it costs nothing.

Three free tools cover most of the ground:

• WAVE (WebAIM) — enter a URL and get a visual overlay showing errors, alerts, and structural elements directly on your page. Ideal for a first pass.
• Lighthouse — built into Chrome DevTools. Right-click anywhere on the page → Inspect → Lighthouse tab → Accessibility. No installation required.
• axe DevTools (Deque Systems, free browser extension) — integrates into Chrome and Firefox with clear explanations and direct code references for each flagged issue.

Run all three tools on your five most-visited pages: the homepage, your main about or services page, the contact page, any donation or sign-up form, and any page in your top navigation. Fix every error flagged by two or more tools.

After automated testing, carry out three manual checks:

1. Keyboard navigation. Set your mouse aside and use Tab to move forward through interactive elements, Shift+Tab to move back, and Enter to activate links and buttons. Can you reach everything? Is there a visible focus indicator showing where you are?
2. Colour contrast. Test every text-and-background combination at colourcontrast.cc.
3. Screen reader test. Windows Narrator and Mac VoiceOver are both free and built in. Listen to your homepage read aloud. Does the structure make sense? Are images described? Do links make sense out of context?

Document what you find. A simple audit log — issue, page, WCAG criterion, fix status — demonstrates due diligence if a complaint is ever made, and keeps remediation on track.

---

Should you publish an accessibility statement?

PSBAR-covered organisations are legally required to publish an accessibility statement. Independent charities are not legally required to do so, but publishing one is strongly recommended.

An accessibility statement tells users and funders that you have considered accessibility, identifies known issues you are working to resolve, and provides a contact route for people who encounter barriers. For grant applications, a published statement increasingly signals that your organisation takes inclusion seriously — a practical competitive advantage in funding rounds.

The Government Digital Service publishes a sample accessibility statement template that any organisation can adapt. It covers scope, known issues, contact information, and a review commitment. It takes approximately an hour to draft.

Place the statement in your site footer under the label "Accessibility." Link to it from your privacy and cookie policy pages.

---

What about PDFs and documents?

A WCAG-compliant website can still create barriers if the documents it links to are inaccessible. PDFs are the main source of the problem.

An untagged PDF — a scanned image of a document, or a Word export made without accessibility settings — is opaque to screen readers. WCAG 2.1 requires that all non-text content has a text equivalent. Annual reports, volunteer application forms, safeguarding policies, and service description leaflets shared as PDFs are all subject to that requirement.

The fix is straightforward for new documents. Microsoft Word and Google Docs both have built-in accessibility checkers (Review → Check Accessibility in Word). Exporting with accessibility settings applied generates a tagged PDF that screen readers can parse. For existing PDFs, AbilityNet publishes free step-by-step guides on remediation. Prioritise the documents your beneficiaries interact with most: main contact forms, service leaflets, and anything linked from your homepage.

---

What is the case for going beyond minimum compliance?

Legal compliance is the floor, not the ceiling. There is a clear practical argument for treating accessibility as an ongoing standard rather than a one-time box to tick.

Accessible websites perform better technically. Descriptive alt text, logical heading hierarchies, semantic HTML, and clear link text are simultaneously WCAG requirements and signals Google uses to understand and rank your content. A site that meets WCAG AA tends to be more crawlable, more readable by AI tools, and better structured for search. This overlap — between clear, well-structured content and visibility in both traditional and AI-driven search — is something we cover in our guide to optimising your website for AI search. The principle is the same: write clearly, structure explicitly, and both your human readers and the algorithms that surface your content benefit.

Funders are raising the bar. The National Lottery Community Fund, local authority commissioning teams, and NHS-contracted services are increasingly including digital accessibility requirements in tender documents and grant conditions. A charity that has documented its WCAG compliance has a practical advantage over one that hasn't.

It extends your reach. The 14.6 million people in the UK with a disability include donors, trustees, volunteers, and service users. An inaccessible site does not just fail them — it signals that they were not considered. For organisations whose mission involves inclusion, that inconsistency is worth addressing on principle as much as on legal grounds.

For charities building or rebuilding a website, embedding accessibility from the outset rather than retrofitting it later is significantly cheaper and more effective. Our web design service builds to WCAG 2.1 AA as standard — accessibility testing is part of the QA process before any site is handed over.

The chart below summarises which obligations apply to which organisations, and what the practical standard is for each.

---

Frequently Asked Questions

Is a small charity legally required to have an accessible website?

Yes. The Equality Act 2010 applies to every organisation that provides services to the public in the UK, including small charities with no paid staff. The duty is anticipatory — you are expected to make adjustments proactively, not wait for someone to raise a complaint. What counts as "reasonable" scales with your size and resources, but inaction is not a reasonable position, particularly when free tools can surface major issues in under an hour.

What is the difference between WCAG 2.1 and WCAG 2.2?

WCAG 2.1 (June 2018) is the current legal baseline in the UK, referenced by PSBAR and used by courts in Equality Act cases. WCAG 2.2 (October 2023) adds nine new success criteria including larger touch targets, accessible authentication that does not rely on cognitive tests, and consistent help mechanisms (W3C, WCAG 2.2). PSBAR has not yet been formally updated to mandate WCAG 2.2. For most charities, achieving full WCAG 2.1 AA compliance is the right first priority — then target 2.2 at the next rebuild or major update.

Does the Equality Act require a formal WCAG compliance certificate?

No such certificate exists. What matters under the Equality Act is demonstrating that your organisation has identified barriers and is taking reasonable steps to address them. An audit log showing what was checked, what was found, and what was fixed — alongside a published accessibility statement with a complaints contact — is more legally useful than any certification and more practically sustainable as the site evolves.

How much does it cost to make a charity website accessible?

For most small charity websites, the highest-impact issues — contrast, alt text, form labels, link text — can be resolved with free tools and in-house effort, with guidance from AbilityNet and the W3C's accessibility introduction. A professional accessibility audit — appropriate before a major rebuild or for large sites serving vulnerable beneficiaries — typically costs £1,500–£5,000 for a comprehensive review with a detailed remediation plan.

What should we do if a user tells us our site is inaccessible?

Respond promptly, investigate the specific issue, and log the date and nature of the complaint. Fix what you can, and reply to the user explaining what you found and what you are doing about it. Organisations that respond constructively to accessibility feedback are in a materially better position — legally and reputationally — than those that ignore it. Keep a log of all accessibility feedback and your responses; it forms part of your ongoing due diligence record.

---

Sources