Equality Act 2010 vs ADA — What's the Difference? 2026

„Is the Equality Act 2010 the UK version of the ADA?" That's a question many UK business owners ask when they hear about web accessibility laws.

In this guide, we'll compare the UK Equality Act 2010 and the US Americans with Disabilities Act (ADA). We'll explain the differences, similarities, and what they mean for your website.

What is the Equality Act 2010?

The Equality Act 2010 is the UK's main anti-discrimination law. It protects people from discrimination in the workplace and wider society. The Act covers nine protected characteristics, including disability.

For websites, the Equality Act requires service providers to make reasonable adjustments for disabled people. This means making your website accessible to disabled users.

Key features of the Equality Act:

• Region: United Kingdom
• In force since: 1 October 2010
• Protected characteristics: 9 (including disability)
• Technical standard: WCAG 2.2 Level AA (recommended by EHRC)
• Enforced by: Equality and Human Rights Commission (EHRC)
• Penalties: Unlimited compensation, EHRC investigations

What is the ADA?

The Americans with Disabilities Act (ADA) is the US's main anti-discrimination law. It was signed into law in 1990 and prohibits discrimination against people with disabilities in all areas of public life.

For websites, the ADA requires that websites are accessible to people with disabilities. This is enforced through Title III of the ADA, which covers public accommodations.

Key features of the ADA:

• Region: United States
• In force since: 1990
• Titles: 5 (I, II, III, IV, V)
• Technical standard: WCAG 2.1 Level AA (DOJ guidance)
• Enforced by: Department of Justice (DOJ), private lawsuits
• Penalties: $10,000–50,000 settlements, DOJ enforcement

Equality Act vs ADA — Direct Comparison

Key Differences Explained

1. Technical Standard

The Equality Act recommends WCAG 2.2 Level AA. The ADA uses WCAG 2.1 Level AA. The difference is that WCAG 2.2 adds 9 new success criteria focused on mobile accessibility, cognitive accessibility, and user privacy.

2. Enforcement

The Equality Act is enforced by the Equality and Human Rights Commission (EHRC) in the UK. The ADA is enforced by the Department of Justice (DOJ) and through private lawsuits in the US.

3. Penalties

The Equality Act can lead to unlimited compensation in discrimination claims. The ADA typically leads to settlements of $10,000–$50,000.

4. Accessibility Statement

Public sector bodies in the UK must publish an accessibility statement. This is not required under the ADA.

5. Exemptions

The Equality Act allows for a „disproportionate burden" exemption. The ADA allows for an „undue burden" exemption — but this is rarely successful in website cases.

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 have similar exemptions — undue/disproportionate burden
• ✅ Both are enforced by government bodies — EHRC vs DOJ

Which law applies to you?

Here's a quick guide to determine which law applies:

1. UK-based website serving UK customers

Equality Act 2010 applies. You must make reasonable adjustments for disabled users.

2. UK-based website serving US customers

Both laws may apply. You must comply with both the Equality Act and the ADA.

3. UK public sector body

PSBAR 2018 applies (under the Equality Act). You must meet WCAG 2.2 Level AA.

4. US-based website serving UK customers

Equality Act applies. You must make reasonable adjustments for UK disabled users.

5. UK website serving EU customers

EAA (European Accessibility Act) also applies. You must meet EN 301 549 (WCAG 2.1 AA).

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.

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 for UK public sector).

Step 4: Document everything

Document all tests and improvements. This serves as evidence for both UK and US enforcement bodies.

Frequently Asked Questions — Equality Act vs ADA

Internal links — UK Accessibility Resources