EAA vs PSBAR — UK Public Sector vs EU Requirements 2026

„What's the difference between the EAA and PSBAR?" That's a question many UK public sector organisations ask when they hear about the new European Accessibility Act.

In this guide, we'll compare the EAA (European Accessibility Act) and the PSBAR (Public Sector Bodies Accessibility Regulations 2018). We'll explain the differences, similarities, and what they mean for UK public sector bodies.

What is the EAA?

The European Accessibility Act (EAA) is an EU law that came into force on 28 June 2025. It requires businesses to make their products and services accessible to people with disabilities.

The EAA applies to all businesses — both private and public — that offer goods or services in the EU. This includes UK public sector bodies if they offer services to EU citizens.

Key features of the EAA:

• Region: EU (27 member states)
• In force since: 28 June 2025
• Technical standard: EN 301 549 (WCAG 2.1 Level AA)
• Applies to: All businesses trading in the EU
• Accessibility statement: Required
• Penalties: Up to €900,000 or 4% of annual turnover

What is PSBAR 2018?

The Public Sector Bodies Accessibility Regulations 2018 (PSBAR) is a UK law that applies specifically to UK public sector bodies. It came into force on 23 September 2018.

PSBAR requires all public sector websites and mobile apps to meet WCAG 2.2 Level AA. It also requires accessibility statements, annual monitoring, and compliance reporting.

Key features of PSBAR:

• Region: United Kingdom
• In force since: 23 September 2018
• Technical standard: WCAG 2.2 Level AA
• Applies to: UK public sector bodies only
• Accessibility statement: Required
• Annual monitoring: Required
• Penalties: EHRC investigations, public notice, legal action

EAA vs PSBAR — Direct Comparison

Key Differences Explained

1. Technical Standard

PSBAR requires WCAG 2.2 Level AA. The EAA requires EN 301 549 (based on WCAG 2.1 Level AA). WCAG 2.2 adds 9 new success criteria compared to WCAG 2.1, focusing on mobile accessibility, cognitive accessibility, and user privacy.

2. Applicability

PSBAR applies to all UK public sector bodies. The EAA applies to UK public sector bodies only if they offer services in the EU.

3. Monitoring and Reporting

PSBAR requires annual monitoring and compliance reporting. The EAA does not specify these requirements.

4. Exemptions

PSBAR has additional exemptions for archived content and pre-2018 documents. The EAA has a micro-enterprise exemption (<10 employees, <€2M turnover).

Similarities Between the Laws

Despite the differences, both laws have important similarities:

• ✅ Both require accessible websites — websites are covered by both laws
• ✅ Both use WCAG as the standard — WCAG 2.2 vs 2.1 is the only difference
• ✅ Both protect disabled people — visual, auditory, motor, cognitive
• ✅ Both require accessibility statements — mandatory under both laws
• ✅ Both have similar exemptions — disproportionate burden

Which law applies to your UK public sector body?

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

1. UK public sector body serving UK citizens only

PSBAR 2018 applies. You must meet WCAG 2.2 Level AA.

2. UK public sector body serving UK + EU citizens

Both laws apply. You must comply with both PSBAR and the EAA.

3. UK public sector body serving EU citizens only

EAA applies (if you offer services in the EU). PSBAR still applies if you have UK citizens.

How to comply with both laws

Step 1: Use a free accessibility checker

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

Step 2: Fix all violations

Follow the recommendations in the report to fix all accessibility violations.

Step 3: Publish an accessibility statement

Publish an accessibility statement on your website (required under both laws).

Step 4: Monitor and update

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

Frequently Asked Questions — EAA vs PSBAR

Internal links — UK Accessibility Resources