EAA vs ADA vs Equality Act — UK Business Comparison 2026

„Which accessibility laws apply to my UK business?" That's a question many UK business owners ask when they learn about the European Accessibility Act, the ADA, and the Equality Act.

In this guide, we'll compare all three laws, explain the differences and similarities, and help you determine which ones apply to your UK business.

Overview — Three Accessibility Laws

UK businesses may need to comply with up to three accessibility laws:

1. Equality Act 2010 — UK Law

The Equality Act 2010 is the UK's main anti-discrimination law. It applies to all UK service providers.

Key features:

• Region: 🇬🇧 United Kingdom
• In force since: 1 October 2010
• Technical standard: WCAG 2.2 Level AA (EHRC recommendation)
• Applies to: All UK businesses
• Key duty: Reasonable adjustments
• Enforcement: Equality and Human Rights Commission (EHRC)
• Penalties: Unlimited compensation
• Exemptions: Disproportionate burden

2. EAA — EU Law

The European Accessibility Act (EAA) is an EU law that applies to businesses trading in the EU.

Key features:

• Region: 🇪🇺 EU (27 member states)
• In force since: 28 June 2025
• Technical standard: EN 301 549 (WCAG 2.1 Level AA)
• Applies to: UK businesses trading in the EU
• Key duty: Accessibility compliance
• Enforcement: EU member state authorities
• Penalties: Up to €900,000 or 4% of turnover
• Exemptions: Micro-enterprises, disproportionate burden

3. ADA — US Law

The Americans with Disabilities Act (ADA) is a US law that applies to businesses with US customers.

Key features:

• Region: 🇺🇸 United States
• In force since: 26 July 1990
• Technical standard: WCAG 2.1 Level AA
• Applies to: UK businesses with US customers
• Key duty: Public accommodation accessibility
• Enforcement: Department of Justice (DOJ), private lawsuits
• Penalties: $10,000–$50,000 settlements
• Exemptions: Undue burden

Direct Comparison — EAA vs ADA vs Equality Act

Key Differences Explained

1. Technical Standard

The Equality Act recommends WCAG 2.2 Level AA (9 new criteria). The EAA uses EN 301 549 (WCAG 2.1 AA). The ADA uses WCAG 2.1 Level AA. WCAG 2.2 is the strictest standard.

2. Applicability to UK Businesses

• Equality Act: Applies to all UK businesses
• EAA: Applies to UK businesses only if they trade in the EU
• ADA: Applies to UK businesses only if they have US customers

3. Penalties

• Equality Act: Unlimited compensation (potentially millions)
• EAA: €900,000 or 4% of turnover
• ADA: $10,000–$50,000 settlements

4. Exemptions

• Equality Act: Disproportionate burden
• EAA: Micro-enterprise (<10 employees, <€2M) + disproportionate burden
• ADA: Undue burden

Similarities Between the Laws

Despite the differences, all three laws have important similarities:

• ✅ All require accessible websites — websites are covered by all three laws
• ✅ All use WCAG as the standard — WCAG 2.2 vs 2.1 is the only difference
• ✅ All protect disabled people — visual, auditory, motor, cognitive
• ✅ All have similar exemptions — disproportionate/undue burden
• ✅ All are enforced by government bodies — EHRC, EU authorities, DOJ

Which laws apply to your UK business?

Here's a quick guide to determine which laws apply:

1. UK business serving UK customers only

Equality Act 2010 applies. EAA and ADA do not apply.

2. UK business serving UK + EU customers

Equality Act + EAA apply. ADA does not apply.

3. UK business serving UK + US customers

Equality Act + ADA apply. EAA does not apply.

4. UK business serving UK + EU + US customers

All three laws apply — Equality Act, EAA, and ADA.

5. UK business serving EU + US customers (no UK)

EAA + ADA apply. Equality Act applies if you have UK presence.

How to comply with all three laws

Step 1: Scan your website

Use the free UK ADA checker to scan your website against WCAG 2.2 Level AA (the highest standard).

Step 2: Fix all violations

Follow the recommendations in the report to fix all violations.

Step 3: Publish an accessibility statement

Publish an accessibility statement on your website (required for EAA and public sector Equality Act).

Step 4: Document everything

Document all tests and improvements. This serves as evidence for all three enforcement bodies.

Step 5: Monitor and update

Monitor your website regularly and update your accessibility statement at least once a year.

Frequently Asked Questions — EAA vs ADA vs Equality Act

Internal links — UK Accessibility Resources