Government guidelines for making websites and apps accessible have been around for years, but they have not always been taken seriously. Monitoring and enforcement have been lax, spotty, or nonexistent.

Meanwhile, government and other public organizations have continued to produce new web content, websites, and mobile apps, all of which suffer from serious accessibility problems.

Recently, the United Kingdom and Northern Ireland began a push to take accessibility much more seriously. The initiative is rooted in existing legislation, specifically the Equality Act of 2010 and Northern Ireland’s Disability Discrimination Act of 1995.

The zeal to provide clear guidelines and back them up with enforcement, however, is new.

The Timeline

According to the new measures, websites launched on or after 2/23/2018 should already meet the accessibility guidelines (as of 2/23/2020). This applies not only to public websites but also to intranets and extranets (so that public employees with disabilities can navigate and operate them).

Organizations creating mobile apps have until 6/23/2021 to become compliant.[1] Any website or mobile app that will be developed after these deadlines should be highly accessible at launch.

Who is Affected

Central government and local government organizations are the primary targets of these new measures. Some charities will also be held to these standards, including those that are publicly funded, provide essential services to the public, and those that pertain to people who have disabilities.[2]

In addition, primary and secondary schools must partially adhere to the guidelines, meaning that websites and apps that are interactive and require public participation should be prioritized.

Accessibility Statements

A particularly interesting aspect of the new measures is the heavy emphasis placed on accessibility statements. An accessibility statement serves as a transparency measure, describing the current state of accessibility for users.

An accessibility statement is not just a boilerplate bit of text that states that an organization strives to make its content accessible (whether or not they actually do). Rather, a quality accessibility statement acknowledges and provides details about strengths and weaknesses.

The guidelines even provide a sample accessibility statement to assist organizations in taking this part of the process seriously. Should you require an accessibility statement, you can generate one for free here and then customize it to meet your needs.

Exceptions and the “Disproportionate Burden” Loophole

Suddenly ramping up enforcement across the board can make it difficult for site and app owners to prioritize what should be fixed first. The new UK measures wisely provide certain exceptions, including:

  • Old pre-recorded video and audio
  • Live streaming video or audio
  • Old PDFs
  • Scanned manuscripts

In large part, these exceptions make sense. It is more reasonable for organizations to focus their accessibility efforts on current content and functionalities. Many organizations cannot bring everything to compliance all at once.

It’s better for everyone if they focus on the relevant and critical content and functionality rather than waste resources on old, irrelevant, or unimportant content.

The measures also allow for a “disproportionate burden” exemption, which is really more of a postponement. If achieving a high level of accessibility for all websites and mobile apps would require such an expenditure of resources that the organization could not continue to fulfill its basic operations, they can get an extension.

This extension does not serve as an excuse for organizations to sidestep accessibility forever. Organizations can simply get more time to adhere to the guidelines so long as they have a solid roadmap in place. All indications are that the UK plans to be quite strict about this.

The bad news is that this “disproportionate burden” loophole can apply to highly critical functionalities. For example, the guidance mentions online forms being eligible for the disproportionate burden extension if those forms are hosted by a third party, which is common.[3]

However, the guidance also mentions that, in such cases, alternative means of accomplishing the same task must be provided. They also state that online forms should ultimately be made highly accessible.


The Government Digital Services (GDS) department will monitor public sector sites. When organizations fail to adhere to the accessibility guidelines, they can be penalized with unlawful act notices and court actions.[4]

Because it would be practically impossible to audit and thoroughly evaluate every public website and mobile app in its entirety, the GDS will make use of sampling on an annual basis. By examining a portion of a site or app, the GDS will then determine whether a given website or app requires further investigation.

The guidance also recommends sampling as a strategy that organizations can use to assess and fix their own sites and apps. While sampling may be useful for catching and solving global problems, it’s vital to choose samples wisely. Serious problems can pop up in selected portions of a site or app.

If not included in the sample, these problems may remain undetected. For example, one form might have accessible labeling while another may not. If the inaccessible form is not included in an assessment sample, it could remain unfixed for years. Luckily, the guidance also urges organizations — and users — to keep lines of communication open. Users are advised to report accessibility problems to help site and app owners identify issues that were missed during their own self-assessments.[5]

It is encouraging to see these changes being made on such a large scale. We will keep you informed as sites and apps see the impact of these regulations and as users begin to benefit from the increases in accessibility.

Note: The content above contains our interpretations and understandings of current guidance and regulations and are not intended as a substitute for information from official channels.