02 Accessibility Legislation


UK

Relevant Acts

Equality Act 2010 is the legislation that states both public and private bodies cannot discriminate against those with a disability. It’s more rigorous for the public sector and there are increased reporting requirements. It doesn’t mention digital accessibility specifically but its broad application includes physical and digital services and resources.

The Public Sector Bodies Accessibility Regulations 2018 (PSBAR) is the legislation that applies to websites and mobile applications, and it only applies to parts of the public sector. Which types of digital content and which organisations within the public sector this act applies to is defined within the legislation, although it is complicated to understand, but there is some simplified guidance here: PSBAR Scope

To be compliant there are 2 components:

Intepretation of whether these acts apply to small diamond open access publishers

We would recommend that PSBAR applies to the eBook files (open and closed) and the website (both the public facing and any backend submission processes) of public sector publishers.

Most diamond OA publishers can be considered public sector, especially if the publisher is part of a public body i.e. a university, but also if the publisher has received public funding to start up, or if any content has received public funding at any part of its creation, for example, it has received public money to fund the research, or the publication of the monograph. Where this is unclear it would be advisable to consider the legislation as applicable anyway to avoid problems. 

If a small publisher is ever very clearly part of the private sector, then it is covered by the Equality Act which makes discrimination towards those with a disability (and other protected characteristics) illegal. This legislation is less specific as to the standards that apply and companies are not audited for compliance, however, providing inaccessible eBooks could be considered discrimination, and, it is never good for business to exclude large numbers of customers or readership. 

This does not constitute legal advice.

More information about legislative requirements:

GOV.uk Equality Guidance - Equality Act 2010: guidance

GOV.uk Digital Accessibility Guidance - Understanding accessibility requirements for public sector bodies

Make Things Accessible - What are the Public Sector Bodies Accessibility Regulations?

Standards referenced in these acts and how they are audited

Web Content Accessibility Guidelines (WCAG) 2.2 AA

The Government publishes detailed information on Accessibility Monitoring: how we test. Your website might be randomly selected to be audited by the Government Digital Service, and if there are any issues, you have to fix these in 12 weeks. The legislation requires regular self-audits, but does not specify a particular frequency - annual can be seen as the default.

More information about auditing:

Government Digital Service 2021 Monitoring report

GOV.uk Accessibility monitoring of public sector websites and mobile apps 2020-2021

AbilityNet - How well have the public sector accessibility regulations been applied?

Accessibility Statements

An accessibility statement should be published on the organisational website. There is some minimal legal wording for the accessibility statement available on a template here: Accessibility Statement Template. This statement needs to be updated annually.

The template requires information about how accessible the website and eBooks are, including details of all known accessibility issues, contact details for use to report any further issues or request additional adjustments, and any exemptions that you are claiming. It also needs to include the enforcement procedure text provided, and this cannot be changed or modified.

It's likely that one accessibility statement would cover a whole publisher, but you could consider having a separate statement for each distinct part of the organisation, for example, one for the website itself and one that just describes the eBook files. You should make the statement very easy to find from the homepage of your website. 

More information about accessibility statements:

Make Things Accessible - Accessibility Statements - what are they?

Make Things Accessible - How to write an accessibility statement

W3C Developing an Accessibility Statement

Examples of accessibility statements:

Open Book Publishers

Leuven University Press

Citizen's Advice

City of York Council

The Open University

Exemptions

The following organisations are exempt from the accessibility regulations:

There is no mention of micro-organisations in UK legislation.

PSBAR does not apply to the following content on websites and mobile applications:

There is also an exemption if accessibility would impose a disproportionate burden, but you’re legally required to carry out an assessment. 

More information about exemptions:

Make Things Accessible - PSBAR Exemptions

How to evidence disproportionate burden

Disproportionate burden is a clause within the accessibility regulations that provides exemptions based on the size and cost of remediation work relative to the organisation. The disproportionate burden clause is appropriate for smaller organisations, and could apply to many small diamond open access publishers.

You may only be able to evidence disproportionate burden for some accessibility aspects and not others. If you are thinking about making a disproportionate burden claim, it must be for something specific that cannot be accomplished, not general inability to consider improving accessibility at all or problems with testing the current accessibility of outputs. You will still need to respond to individual accessibility requests even if you are exempt due to disproportionate burden.

Organisations are legally required to carry out an assessment of the extent to which compliance with the accessibility regulations imposes a disproportionate burden. You cannot claim disproportionate burden without having completed and documented an assessment first. In essence you are not exempt until the assessment is completed.

Disproportionate Burden Assessments

Overall, a disproportionate burden assessment is balancing the burden that making those things accessible places on your organisation versus the benefits of making those things accessible.

You should describe:

You should analyse:

You should also:

What Makes a ‘Good’ Disproportionate Burden Assessment?

Some ways of evidencing disproportionate burden are to be avoided. In the 2021 report linked below, GDS specifically stated, “Lack of time or knowledge does not constitute a disproportionate burden.”

According to the 2020-2021 accessibility monitoring of public sector websites review, common issues with assessments include:

Within the AllAble research linked below, there are some further descriptions of bad practices encountered after requesting to see assessments:

Many of these approaches highlighted as bad practice seem reasonable, but it is not enough within the legislation to consider it to be 'obvious' that accessibility issues have remained unfixed due to disproportionate burden. Even when very obviously out of reach for an organisation it must be assessed and evidenced, and if it really is that obvious then it should not be too difficult to demonstrate.

More information about disproportionate burden:

GOV.uk Digital Accessibility Guidance - When complying with accessibility regulations might be a ‘disproportionate burden’

DfE Accessibility and Inclusive Design Manual - disproportionate burden

2020-2021 PSBAR Monitoring Review

Make Things Accessible - understanding disproportionate burden

Make Things Accessible – how to write a disproportionate burden assessment

All Able 2020 Disproportionate burden misuse research

George Rhodes - an in depth article on disproportionate burden

Examples of disproportionate burden assessments:

GOV.uk Sample accessibility statement (for a fictional public sector website)

Equality and Human Rights Commission

Manchester City Council

University of Bradford

Cardiff and Vale University Health Board

EU

Relevant Acts

The European Accessibility Act (EAA) is the legislation that states some products and services need to be accessible to those with disabilities. It includes a wide range of devices and online based digital products and services including e-readers, computers, smartphones, payment terminals, websites and access to audio-visual media. It includes all economic providers/economic operators which includes both the public and private sector. It is based on the UN Convention on the Rights of Persons with Disabilities and was passed in 2019, and comes into force on 28 June 2025. The EAA does not specify a technical standard and leaves compliance details down to member states. It is often advised to presume WCAG AA compliance plus a published accessibility statement is the default.

There is also a separate EU Web Accessibility Directive, which applies to public sector websites and apps (and downloadable/embedded documents on them), and is applicable in all countries in Europe and in the European Economic Area. This is applicable to organisations selling to the public sector as well, but just includes online experiences, rather than digital hardware as in the EAA.

The directive requires:

The European standard for accessibility requirements for ICT products and services is called EN 301 549. Complying with this standard is a way for public sector bodies to meet the mandatory technical requirements of the current Web Accessibility Directive. New requirements in future versions of EN 301 549 or WCAG will not automatically become legally relevant to the Web Accessibility Directive. This will only be the case if these new requirements are included in Annex A of a new harmonised version of EN 301 549. It is expected that new versions of Annex A will align with Web Content Accessibility Guidelines (WCAG) 2.2 AA.

The EU Web Accessibility Directive was transposed into national law in all EU member states; you can check the full list of national transposition measures.

The Academic Network of European Disability Experts (ANED) maintains a searchable database on disability-related national laws, policies, strategies and initiatives in EU Member States, candidate countries and other associated countries. Accessibility is one of eight topics monitored. The data is compiled by ANED’s independent country experts, under the guidance of the network’s Scientific Director, and updated periodically.

The W3C Web Accessibility Initiative (WAI) maintains an international list of laws and policies in different countries.

Intepretation of whether these acts apply to small diamond open access publishers

European Accessibility Act

Seeing as the EAA applies to both the public and private sector as long as they are economic operators (as in, an organisation providing products and services, one that needs money to run) then yes EAA applies to diamond open access publishers, but only if there are more than 10 employees AND an annual turnover of more than EUR 2 million. Anything else the legislation refers to as a 'micro-enterprise' making them automatically exempt, which many small publishers will be classed as.

If these organisational limits are exceeded, then the EAA specifically references eBooks, "In the context of e-books, the concept of a service provider could include publishers and other economic operators involved in their distribution." This is not the clearest description of applicability, and it includes the word 'could', and given this it would be advisable to consider the legislation as applicable anyway to avoid problems (but only if you're not classed as a micro-enterprise). 

EU Web Accessibility Directive

The Web Accessibility Directive defines the public sector as:

Therefore, the Web Accessibility Directive applies if the publisher is part of a public body i.e. a university, but probably also if the publisher has received public funding to start up, or if any content has received public funding at any part of its creation, for example, it has received public money to fund the research, or the publication of the monograph. Where this is unclear, again it would be advisable to consider the legislation as applicable anyway to avoid problems. The legislation covers websites, and embedded or downloadable files from them.

This does not constitute legal advice.

More information about legislative requirements:

AbilityNet - European Accessibility Act

Digital Accessibility Centre - The European Accessibility Act: Understanding Digital Accessibility

Web Accessibility Directive: Frequently Asked Questions

European Commission - Web Accessibility

European Disability Forum - Web Accessibility Directive

Standards referenced in these acts and how they are audited

The current EAA requirements align with Web Content Accessibility Guidelines (WCAG) 2.1 AA, but the new updated version that comes into force in 2025 is widely interpreted as aligning with Web Content Accessibility Guidelines (WCAG) 2.2 AA. Individual member states may have further specified technical standards.

EN 301 549 Annex A is the standard required to be compliant with EU Web Accessibility Directive, and it is roughly similar to WCAG 2.1 AA. Annex A also includes additional requirements that are not part of WCAG 2.1. Therefore, demonstrating that a website meets all the success criteria of WCAG 2.1 is not sufficient to provide a presumption of conformity with the Web Accessibility Directive.

National authorities will be responsible for carrying out regular monitoring, including reviewing complaints and following up on any reported non-compliance. The European Commission set out a methodology for monitoring for the Web Accessibility Directive which specifies either:

  1. an in-depth monitoring method to verify compliance, in accordance with the requirements listed in point 1.2 
  2. a simplified monitoring method to detect non-compliance, in accordance with the requirements listed in point 1.3

The monitoring methodology also describes how to carry out the sampling of websites and mobile applications, and describes what Member States must provide in their monitoring reports, including:

More information about auditing:

European Commission - A monitoring methodology and the arrangements for reporting by Member States

W3C Web Accessibility Laws & Policies by Country

Web Accessibility Directive - Member States Published Monitoring reports 2022-2024 

Member States' bodies in charge of monitoring the Web Accessibility Directive

Accessibility Statements

The Web Accessibility Directive requires public sector bodies to provide and regularly update a ‘detailed, comprehensive and clear’ accessibility statement on their website or mobile application.

The accessibility statement must include the following information:

The accessibility statement can also include optional content, for example:

The declarations made in the accessibility statement should be accurate and based on one of the following:

The statement should indicate the method used.

There is a model accessibility statement in European Commission - A monitoring methodology and the arrangements for reporting by Member States. It provides more detail on mandatory and optional content requirements.

More information about accessibility statements:

W3C Developing an Accessibility Statement

Examples of accessibility statements:

Leuven University Press

European Commission

ENCA Network

Competition and Consumer Protection Commission

Agence Française de Développement

Exemptions

European Accessibility Act

Microenterprises with less than 10 employees and an annual turnover less than EUR 2 million or an annual balance sheet total less than EUR 2 million are exempt from the EAA accessibility requirements for services. They are also exempted from the requirement to document their assessment.

The EAA does not apply to the following content on websites and mobile applications:

EU Web Accessibility Directive

Exemptions relating to the scope:

Exemptions regarding specific types of content:

The Web Accessibility Directive also states that delivering accessibility requirements should not impose a ‘disproportionate burden’ on public sector bodies.

More information about exemptions:

International Publishers Association - The European Accessibility Act for non-EU members

How to evidence disproportionate burden

The disproportionate burden clause appeara within both the European Accessibility Act and the EU Web Accessibility Directive, and it is designed to balance accessibility with the practical limitations of some organisations where the cost of compliance may be too high. National authorities set requirements around the reporting and reviewing of assessments, and applying penalties for non compliance.

Disproportionate Burden Assessments

European Accessibility Act

Annex VI states specific analyses that must be completed as part of any disproportionate burden assessment.

  1. Ratio of the net costs of compliance with accessibility requirements to the overall costs (operating and capital expenditures) of manufacturing, distributing or importing the product or providing the service for the economic operators.
  2. The estimated costs and benefits for the economic operators, including production processes and investments, in relation to the estimated benefit for persons with disabilities, taking into account the amount and frequency of use of the specific product or service.
  3. Ratio of the net costs of compliance with accessibility requirements to the net turnover of the economic operator.
EU Web Accessibility Directive

This legislation requires similar information in disproportionate burden assessments.

  1. The organisation's size, resources and nature;
  2. The estimated costs and benefits for the organisation in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the specific website.

What Makes a ‘Good’ Disproportionate Burden Assessment?

According to the Web Accessibility Directive, measures that would impose a disproportionate burden should be understood as measures that would impose an ‘excessive organisational or financial burden’ on a public sector body, or would ‘jeopardise the body's capacity to either fulfil its purpose or to publish information needed for or relevant to its tasks and services, while taking into account the likely resulting benefit or detriment for citizens, in particular persons with disabilities’.

The Web Accessibility Directive states that ‘lack of priority, time or knowledge’, and that not procuring or developing accessible software systems, are both not legitimate reasons for claiming disproportionate burden.

If public sector bodies make use of the ‘disproportionate burden’ clause, they have to explain in the accessibility statement which parts of the accessibility requirements could not be complied with and provide accessible alternatives.

More information about disproportionate burden:

accessible.org Disproportionate Burden Exception under The EAA

Web Accessibility Directive: Frequently Asked Questions

Examples of disproportionate burden claims:

https://www.interreg-central.eu/jems-accessibility-statement/

https://www.eesc.europa.eu/en/accessibility-statement

US

Relevant Acts

The Americans with Disabilities Act (ADA) is the legislation that states both ‘state and local government entities’ (Title II) and private/business entities that are open to the public (Title III) cannot discriminate against those with a disability. Title II states that disabled individuals must be able to access and use web content through compliance with WCAG 2.1 AA.

Section508 within the Rehabilitation Act is the legislation that applies to all electronic and information technology from federal agencies. To be compliant you have to meet the Web Content Accessibility Guidelines (WCAG) 2.0 AA accessibility standard, and this will be updated to require the Web Content Accessibility Guidelines (WCAG) 2.1 AA standard from 24th April 2026. 

The Office of Management and Budget (OMB) memorandum on “Strengthening Digital Accessibility and the Management of Section 508 of the Rehabilitation Act“ (M-24-08) requires federal agencies to maintain an accessibility statement on their websites. 

The Nelson Memo also states that peer reviewed scholarly content should be available in such a format so that it is, “...enabling broad accessibility through assistive devices.”

Intepretation of whether these acts apply to small diamond open access publishers

Title II applies to all services, programs, and activities provided or made available by public entities, which are defined as: (A) any State or local government; (B) any department, agency, special purpose district, or other instrumentality of a State or States or local government; and (C) the National Railroad Passenger Corporation, and any commuter authority (as defined in section 24102(4) of title 49). Title II also specifically includes a section on web and mobile accessibility, which applies to all 'web content'.

Most diamond OA publishers can be considered public entities, especially if the publisher is part of a public body i.e. a university, but also if the publisher has received public funding to start up, or if any content has received public funding at any part of its creation, for example, it has received public money to fund the research, or the publication of the monograph. Where this is unclear it would be advisable to consider the legislation as applicable anyway to avoid problems. Section508 similarly applies only to federal agencies.

Title III applies to all private entities offering services to the public, which all open content can be considered to be, and alongside the Nelson Memo means that accessibility needs to be considered in general (both Title III and the Nelson Memo do not specify a digital accessibility standard).

More information about legislative requirements:

ADA.gov

ADA National Network - What is the Americans with Disabilities Act (ADA)?

ADA.gov Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments

Section508.gov

Standards referenced in these acts and how they are audited

Web Content Accessibility Guidelines (WCAG) 2.0 AA

Web Content Accessibility Guidelines (WCAG) 2.1 AA

Agencies subject to Section 508 are required to report on the implementation of Section 508 to the Office of Management and Budget (OMB) and the General Services Administration (GSA) through the Annual Section 508 Assessment. A primary point of contact will be appointed, and this person will receive details of access to an online assessment reporting tool.

More information about auditing:

Section508.gov Government-wide Section 508 Assessment

Accessibility Statements

An accessibility statement should be published on the organisational website, which needs to include the following:

  1. The accessibility standard applied to the website and any known limitations or alternative versions, as appropriate.
  2. The contact information for the Section 508 program manager (name and email address).
  3. A public feedback mechanism that allows members of the public to report accessibility problems with agency websites and digital services to the agency’s Section 508 program as well as relevant implementation teams.
  4. Instructions for filing a complaint alleging a violation of Section 508.
  5. Information about the agency’s reasonable accommodations procedures for Federal employees and job applicants, consistent with Section 501 of the Rehabilitation Act.
  6. Instructions on the use of the telecommunications relay service.
  7. Links to any relevant, publicly available organizational policies or procedures on digital accessibility.
  8. Date that the digital accessibility statement was last updated or reviewed.

The statement should be linked to from the footer at the bottom of every web page. 

More information about accessibility statements:

Section508.gov Developing a Website Accessibility Statement

W3C Developing an Accessibility Statement

Examples of accessibility statements:

General Services Administration (GSA) Accessibility Statement

U.S. Nuclear Regulatory Commission (NRC) Accessibility Statement

US Department of Commerce

Exemptions

ADA and Title III

This legislation does not apply to private clubs or to religious organisations or entities controlled by religious organisations, including places of worship or schools.

Title II Web and Mobile Accessibility

The requirements do not apply to the following:

Section 508

The requirements do not apply to the following

There is no mention of micro-organisations in US legislation.

More information about exemptions:

accessible.org Web Content Exceptions Under New Title II Rule

Section 508.gov Determine ICT Exceptions

How to evidence undue burden

The undue burden exception applies only to the specific features or functions of the ICT that cannot be made to conform without imposing an undue burden on the agency or component. The federal agency or component that owns (or will own) the ICT product or service must:

If the answer to all questions is ”yes”, your ICT may warrant this exception.

  1. Have you determined that conformance for some or all features and functions of the ICT item would result in an undue burden on your agency or component?
  2. Have you quantified the resources available to the program or component for which the ICT is to be procured, developed, maintained, or used?
  3. Has the responsible agency official documented in writing how the difficulty or expense is significant, relative to the resources available? For example:
    1. What % of the expense equals total budget available?
    2. Explain exactly what is significantly difficult, and why.
  4. Does your documentation address whether the exception is being claimed for the entire ICT Item, or only specific features and functions?
  5. Will the agency provide an alternative means for users with disabilities for the features and functions for which you are claiming this exception?

Undue Burden Assessments

What Makes a ‘Good’ Undue Burden Assessment?

More information about undue burden:

Section 508.gov Determine ICT Exceptions

convergeaccessibility.com How to Comply with DOJ’s Seemingly Impossible Web Accessibility Regulation

Examples of undue burden claims: