UK Court of Appeal: Website Accessibility Falls Under Equality Act 2010
In a July 2025 judgment, the UK Court of Appeal definitively ruled that the Equality Act 2010 imposes a duty on service providers to ensure their websites are accessible to disabled users. The ruling is the highest-level UK court decision on digital accessibility to date and establishes WCAG 2.1 AA as the expected compliance standard.
The Case
The case involved a blind user who was unable to complete an online transaction due to screen reader incompatibility and low color contrast on a major retailer's website. The retailer argued that the Equality Act's 'reasonable adjustments' requirement was satisfied by offering telephone support as an alternative. The Court of Appeal rejected this argument, holding that 'reasonable adjustments' includes making the primary digital channel accessible — not just providing an offline alternative.
Key Holdings
The court held: (1) websites providing services to the public are 'service providers' under the Equality Act; (2) the duty to make reasonable adjustments applies to website design and functionality; (3) offering an alternative channel (phone, in-person) does not satisfy the duty if the primary digital channel remains inaccessible; (4) WCAG 2.1 AA is the appropriate benchmark for determining whether a website meets the reasonableness standard, though it is not codified into law.
Color Contrast in the Judgment
The judgment specifically noted that the retailer's website had a contrast ratio of 3.2:1 for body text against its background — below the WCAG 2.1 AA requirement of 4.5:1. The court found that fixing this issue would have been 'straightforward and inexpensive,' making the failure to do so unreasonable under the Equality Act. This is the first UK appellate decision to explicitly reference a specific contrast ratio as evidence of unreasonable failure to accommodate.
Implications
UK service providers should now assume that WCAG 2.1 AA compliance is legally required, not optional. The 'we have a phone number' defense no longer works — digital services must be accessible in their own right. Given that color contrast fixes are among the cheapest and fastest accessibility improvements, courts are particularly unsympathetic to arguments that they're burdensome.
The ruling aligns UK digital accessibility law more closely with the EU's European Accessibility Act, though the UK operates under its own post-Brexit legal framework. Businesses operating in both markets will find WCAG 2.1 AA compliance satisfies both regulatory regimes.