Reasonable Adjustments for Websites — UK Equality Act Duty 2026
„What does 'reasonable adjustments' mean for my website under the Equality Act?" That's a question many UK business owners ask when they hear about their legal obligations.
In this guide, we'll explain what reasonable adjustments are, how they apply to websites, and what you need to do to comply with the Equality Act 2010.
📌 Quick Answer — Reasonable Adjustments
The Equality Act 2010 requires service providers to make reasonable adjustments for disabled people. For websites, this means making your content accessible to disabled users. What is „reasonable" depends on the size and resources of your organisation.
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The Equality Act 2010 requires service providers to make reasonable adjustments for disabled people. The duty is set out in Section 20 of the Act.
The duty has three requirements:
- 1. Changing the way things are done — e.g., providing information in accessible formats
- 2. Making physical changes — e.g., to premises
- 3. Providing auxiliary aids — e.g., screen readers, accessible documents
For websites, this means making your content and functionality accessible to disabled users.
📊 Reasonable Adjustments — Key Facts
- Based on: Section 20 of the Equality Act 2010
- Applies to: All service providers (public and private)
- What it means: Make adjustments so disabled people are not at a substantial disadvantage
- What is reasonable: Depends on size, resources, and cost
- Technical standard: EHRC recommends WCAG 2.2 Level AA
How does the duty apply to websites?
The duty applies to websites in the following ways:
1. Information provision
You must provide information in accessible formats. This means:
- Alternative text for all images (WCAG 1.1.1)
- Captions for all videos (WCAG 1.2.2)
- Accessible PDFs for documents (WCAG 1.1.1)
- Clear and simple language for easy understanding (WCAG 3.1.5)
2. Functionality
Your website's functionality must be accessible:
- Keyboard accessibility — all functions with Tab key (WCAG 2.1.1)
- Form accessibility — all fields with labels (WCAG 3.3.2)
- Error messages — clear and descriptive (WCAG 3.3.1)
- Navigation — consistent and logical (WCAG 2.4.3)
3. Communication
You must communicate effectively with disabled users:
- Contact options — multiple ways to contact you (phone, email, web form)
- Response times — responding to accessibility queries promptly
- Alternative formats — offering documents in alternative formats on request
What does „reasonable" mean?
„Reasonable" depends on the circumstances. Factors that determine what is reasonable include:
1. Size and resources of your organisation
A large corporation can be expected to do more than a small business. For example, a multinational company must invest more than a local shop.
2. Cost of the adjustments
If the cost is high, it may be unreasonable. However, you must assess the cost and document it.
3. Benefit to disabled users
If the adjustment would benefit many disabled users, it is more likely to be reasonable.
4. Disruption
If the adjustment would cause significant disruption, it may be unreasonable.
5. Resources available
If you have the resources to make the adjustment, it is more likely to be reasonable.
⚠️ Important — The duty is anticipatory
The duty to make reasonable adjustments is anticipatory. This means you cannot wait for a disabled person to request an adjustment — you must proactively make your website accessible.
For websites, this means you must test your website for accessibility and fix problems before they affect users.
What is the technical standard?
The Equality Act does not specify a technical standard for websites. However, the Equality and Human Rights Commission (EHRC) recommends WCAG 2.2 Level AA as the standard to aim for.
Why WCAG 2.2 AA?
- Recognised international standard — accepted by courts and tribunals
- Comprehensive — covers all types of disabilities
- Testable — can be measured and verified
- Up-to-date — includes mobile and cognitive accessibility
What are the consequences of not making adjustments?
Failure to make reasonable adjustments can lead to serious consequences:
1. Discrimination claims
Disabled users can bring a discrimination claim against you in the county court. If successful, you could be ordered to pay unlimited compensation.
2. EHRC investigations
The EHRC can investigate your website and issue a non-discrimination notice. If you don't comply, they can take you to court.
3. Reputational damage
Accessibility failures can lead to negative publicity and loss of customers.
4. Legal costs
Defending a discrimination claim can be expensive, even if you win.
How to make reasonable adjustments — Step by step
Step 1: Scan your website
Use the free UK ADA checker to scan your website against WCAG 2.2 Level AA. You'll get a report within 60 seconds with violations, warnings, and solutions.
Step 2: Fix all violations
Follow the recommendations in the report to fix all violations. Focus on critical issues first:
- Alt text for all images
- Colour contrast — at least 4.5:1
- Keyboard accessibility — all functions with Tab key
- Form labels — all fields with labels
- Headings structure — logical H1-H6 hierarchy
Step 3: Publish an accessibility statement
Publish an accessibility statement on your website explaining how accessible your website is and how users can report problems.
Step 4: Document everything
Document all tests and improvements. This serves as evidence that you have made reasonable adjustments.
Step 5: Monitor and update
Monitor your website regularly and update your accessibility statement at least once a year.
What counts as a disproportionate burden?
A disproportionate burden is an exemption from the reasonable adjustments duty if the cost of making an adjustment is too high compared to the benefits.
Factors to consider:
- Financial cost — How much would it cost?
- Organisational resources — Can you afford it?
- Time — How long would it take?
- Impact on users — Would the burden outweigh the benefits?
You must document your assessment
If you claim a disproportionate burden, you must document your assessment. This includes:
- What you assessed
- Why you concluded it was disproportionate
- What alternatives you considered
Important: Claiming a disproportionate burden is not a permanent excuse. You should review the situation regularly and make adjustments when possible.
Frequently Asked Questions — Reasonable Adjustments
Reasonable adjustments are changes that service providers must make to ensure disabled people are not at a substantial disadvantage. For websites, this means making your content accessible to disabled users.
The Equality Act does not specify a technical standard, but the EHRC recommends WCAG 2.2 Level AA as the standard to aim for.
A disproportionate burden is an exemption from the reasonable adjustments duty if the cost of making an adjustment is too high compared to the benefits. You must document your assessment.
No. The duty is anticipatory. You must proactively make your website accessible — you cannot wait for a complaint.
Penalties include discrimination claims with unlimited compensation, EHRC investigations, reputational damage, and legal costs.
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