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Number of posts in this thread: 9 (In chronological order)

From: Jim Byrne Accessible Web Design
Date: Fri, Apr 04 2025 3:56AM
Subject: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
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From: Julian Tenney
Date: Fri, Apr 04 2025 4:08AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
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Note that in the UK we have not adopted the EAA directive through legislation, and there is no enforcement agency, so it remains to be seen how the act would actually be enforced.

Julian

From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Jim Byrne Accessible Web Design via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
Sent: 04 April 2025 10:56
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Cc: Jim Byrne Accessible Web Design < = EMAIL ADDRESS REMOVED = >
Subject: [WebAIM] Have I got all of these legal requirements and de facto requirement correct for private sector businesses

Hi,

I=92m writing a piece of text I can add to my website and proposals relating to UK and EU requirements. Can I just check I have got this information correct:

A note about UK compliance
The relevant acts in the UK are the Equality Act 2010 and The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. Note that privately owned businesses do not fall within requirement of The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

While WCAG 2.2 is not itself a law, it is the de facto standard used to assess compliance. The UK government has adopted WCAG 2.2 AA as the benchmark for public sector accessibility, and it is widely recognised as the standard to follow for all organisations aiming to meet legal accessibility requirements.

The relevant UK Government website page to have a look at is at https://www.gov.uk/guidance/meet-the-requirements-of-equality-and-accessibility-regulations

Accessibility Statements
Private sector businesses not legally required to publish an accessibility statement. However, under the Equality Act 2010, businesses must not discriminate against disabled users. A accessibility statement can help demonstrate awareness and a commitment to meeting those duties.

From June 2025: the European Accessibility Act (EAA)
The EAA will apply accessibility obligations to many private sector businesses, especially those providing key digital and consumer services across the EU. This includes:

=95 E-commerce websites and apps
=95 Banking services
=95 Transport (ticketing and travel info)
=95 Telecoms
=95 ATMs, ticket machines, check-in terminals
=95 E-book readers and e-publishing
=95 Audiovisual media services
=95 Computer hardware and software

Even non-EU companies will be affected if they sell to EU consumers.

VPAT Templates
A VPAT (Voluntary Product Accessibility Template) is not a legal requirement, but it becomes a de facto requirement when selling digital products or services to public sector bodies. It has also become common for large organisations to expect a VPAT to be provided.

I=92d appreciate your feedback. Thanks.

Jim


[cid: = EMAIL ADDRESS REMOVED = ]


Multi-award-winning WCAG 2.2 AA Accessibility Auditing and Accessibility Consultant

Web: https://jimbyrne.co.uk

Jim Byrne is one of the UK=92s most experienced practitioners in the area of accessible digital design.

Jim provided feedback during the development of WCAG 2 (the de facto accessibility guidelines used by governments across the world). He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.


This message and any attachment are intended solely for the addressee and may contain confidential information. If you have received this message in error, please contact the sender and delete the email and attachment. Any views or opinions expressed by the author of this email do not necessarily reflect the views of the University of Nottingham. Email communications with the University of Nottingham may be monitored where permitted by law.

From: Jim Byrne Accessible Web Design
Date: Fri, Apr 04 2025 4:15AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
← Previous message | Next message →

Thanks Julian.

That’s good to know. However, I guess UK businesses will need to comply if they want/expect to work with EU members?

Jim

> On 4 Apr 2025, at 11:08, Julian Tenney via WebAIM-Forum < = EMAIL ADDRESS REMOVED = > wrote:
>
> Note that in the UK we have not adopted the EAA directive through legislation, and there is no enforcement agency, so it remains to be seen how the act would actually be enforced.
>
> Julian
>
> > From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Jim Byrne Accessible Web Design via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
> Sent: 04 April 2025 10:56
> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> Cc: Jim Byrne Accessible Web Design < = EMAIL ADDRESS REMOVED = >
> Subject: [WebAIM] Have I got all of these legal requirements and de facto requirement correct for private sector businesses
>
> Hi,
>
> I’m writing a piece of text I can add to my website and proposals relating to UK and EU requirements. Can I just check I have got this information correct:
>
> A note about UK compliance
> The relevant acts in the UK are the Equality Act 2010 and The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. Note that privately owned businesses do not fall within requirement of The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.
>
> While WCAG 2.2 is not itself a law, it is the de facto standard used to assess compliance. The UK government has adopted WCAG 2.2 AA as the benchmark for public sector accessibility, and it is widely recognised as the standard to follow for all organisations aiming to meet legal accessibility requirements.
>
> The relevant UK Government website page to have a look at is at https://www.gov.uk/guidance/meet-the-requirements-of-equality-and-accessibility-regulations
>
> Accessibility Statements
> Private sector businesses not legally required to publish an accessibility statement. However, under the Equality Act 2010, businesses must not discriminate against disabled users. A accessibility statement can help demonstrate awareness and a commitment to meeting those duties.
>
> From June 2025: the European Accessibility Act (EAA)
> The EAA will apply accessibility obligations to many private sector businesses, especially those providing key digital and consumer services across the EU. This includes:
>
> • E-commerce websites and apps
> • Banking services
> • Transport (ticketing and travel info)
> • Telecoms
> • ATMs, ticket machines, check-in terminals
> • E-book readers and e-publishing
> • Audiovisual media services
> • Computer hardware and software
>
> Even non-EU companies will be affected if they sell to EU consumers.
>
> VPAT Templates
> A VPAT (Voluntary Product Accessibility Template) is not a legal requirement, but it becomes a de facto requirement when selling digital products or services to public sector bodies. It has also become common for large organisations to expect a VPAT to be provided.
>
> I’d appreciate your feedback. Thanks.
>
> Jim
>
>
> [cid: = EMAIL ADDRESS REMOVED = ]
>
>
> Multi-award-winning WCAG 2.2 AA Accessibility Auditing and Accessibility Consultant
>
> Web: https://jimbyrne.co.uk
>
> Jim Byrne is one of the UK’s most experienced practitioners in the area of accessible digital design.
>
> Jim provided feedback during the development of WCAG 2 (the de facto accessibility guidelines used by governments across the world). He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.
>
>
> This message and any attachment are intended solely for the addressee and may contain confidential information. If you have received this message in error, please contact the sender and delete the email and attachment. Any views or opinions expressed by the author of this email do not necessarily reflect the views of the University of Nottingham. Email communications with the University of Nottingham may be monitored where permitted by law.
> <PastedGraphic-3.png>




Multi-award-winning WCAG 2.2 AA Accessibility Auditing and Accessibility Consultant

Web: https://jimbyrne.co.uk

Jim Byrne is one of the UK’s most experienced practitioners in the area of accessible digital design.

Jim provided feedback during the development of WCAG 2 (the de facto accessibility guidelines used by governments across the world). He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.

From: Julian Tenney
Date: Fri, Apr 04 2025 4:20AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
← Previous message | Next message →

Yes, and that's what we are seeing in the University sector: publishers are taking it very seriously, so that's a major benefit, we're also seeing organisations like banks starting to take it all a lot more seriously, HSBC recently sponsored some training for the HE sector with Hassell Inclusion, it was the training they are using internally, so they are getting involved, and I recently spotted some sign language signs at train stations, which is very much in the spirit of the EAA,

Julian
From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Jim Byrne Accessible Web Design via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
Sent: 04 April 2025 11:15
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Cc: Jim Byrne Accessible Web Design < = EMAIL ADDRESS REMOVED = >
Subject: Re: [WebAIM] Have I got all of these legal requirements and de facto requirement correct for private sector businesses

Thanks Julian.

That’s good to know. However, I guess UK businesses will need to comply if they want/expect to work with EU members?

Jim

> On 4 Apr 2025, at 11:08, Julian Tenney via WebAIM-Forum < = EMAIL ADDRESS REMOVED = > wrote:
>
> Note that in the UK we have not adopted the EAA directive through legislation, and there is no enforcement agency, so it remains to be seen how the act would actually be enforced.
>
> Julian
>
> > From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Jim Byrne Accessible Web Design via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
> Sent: 04 April 2025 10:56
> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> Cc: Jim Byrne Accessible Web Design < = EMAIL ADDRESS REMOVED = >
> Subject: [WebAIM] Have I got all of these legal requirements and de facto requirement correct for private sector businesses
>
> Hi,
>
> I’m writing a piece of text I can add to my website and proposals relating to UK and EU requirements. Can I just check I have got this information correct:
>
> A note about UK compliance
> The relevant acts in the UK are the Equality Act 2010 and The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. Note that privately owned businesses do not fall within requirement of The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.
>
> While WCAG 2.2 is not itself a law, it is the de facto standard used to assess compliance. The UK government has adopted WCAG 2.2 AA as the benchmark for public sector accessibility, and it is widely recognised as the standard to follow for all organisations aiming to meet legal accessibility requirements.
>
> The relevant UK Government website page to have a look at is at https://www.gov.uk/guidance/meet-the-requirements-of-equality-and-accessibility-regulations
>
> Accessibility Statements
> Private sector businesses not legally required to publish an accessibility statement. However, under the Equality Act 2010, businesses must not discriminate against disabled users. A accessibility statement can help demonstrate awareness and a commitment to meeting those duties.
>
> From June 2025: the European Accessibility Act (EAA)
> The EAA will apply accessibility obligations to many private sector businesses, especially those providing key digital and consumer services across the EU. This includes:
>
> • E-commerce websites and apps
> • Banking services
> • Transport (ticketing and travel info)
> • Telecoms
> • ATMs, ticket machines, check-in terminals
> • E-book readers and e-publishing
> • Audiovisual media services
> • Computer hardware and software
>
> Even non-EU companies will be affected if they sell to EU consumers.
>
> VPAT Templates
> A VPAT (Voluntary Product Accessibility Template) is not a legal requirement, but it becomes a de facto requirement when selling digital products or services to public sector bodies. It has also become common for large organisations to expect a VPAT to be provided.
>
> I’d appreciate your feedback. Thanks.
>
> Jim
>
>
> [cid: = EMAIL ADDRESS REMOVED = ]
>
>
> Multi-award-winning WCAG 2.2 AA Accessibility Auditing and Accessibility Consultant
>
> Web: https://jimbyrne.co.uk
>
> Jim Byrne is one of the UK’s most experienced practitioners in the area of accessible digital design.
>
> Jim provided feedback during the development of WCAG 2 (the de facto accessibility guidelines used by governments across the world). He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.
>
>
> This message and any attachment are intended solely for the addressee and may contain confidential information. If you have received this message in error, please contact the sender and delete the email and attachment. Any views or opinions expressed by the author of this email do not necessarily reflect the views of the University of Nottingham. Email communications with the University of Nottingham may be monitored where permitted by law.
> <PastedGraphic-3.png>




Multi-award-winning WCAG 2.2 AA Accessibility Auditing and Accessibility Consultant

Web: https://jimbyrne.co.uk

Jim Byrne is one of the UK’s most experienced practitioners in the area of accessible digital design.

Jim provided feedback during the development of WCAG 2 (the de facto accessibility guidelines used by governments across the world). He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.


This message and any attachment are intended solely for the addressee and may contain confidential information. If you have received this message in error, please contact the sender and delete the email and attachment. Any views or opinions expressed by the author of this email do not necessarily reflect the views of the University of Nottingham. Email communications with the University of Nottingham may be monitored where permitted by law.

From: Steve Green
Date: Fri, Apr 04 2025 4:31AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
← Previous message | Next message →

The EU has no jurisdiction outside the EU countries (although it doesn't seem to understand this) so there are limits to what they can do if your website does not conform with the EAA. For instance, they can't force you to attend court, and there is no chance our government would consider an extradition request.

However, they can demand that you cease the provision of your services to the EU. They could even block traffic to your website from EU countries, although I expect they would only do this for very large organisations like Google and Amazon. And in theory, they might be able to arrest you if you set foot in an EU country, although I think this is extremely unlikely. Small and medium size organisations are likely to just go under the radar.

It's worth noting that the EU regards the EAA as applying to EU citizens regardless of where they are in the world. If you provide a service to EU citizens but only outside the EU, then there really is nothing the EU can do to enforce their law.

With regard to VPATs, I wouldn't say they are "a de facto requirement when selling digital products or services to public sector bodies". I have worked for some of these third parties, and I am in a UK government discussion group on accessibility, and VPATs are rarely mentioned. That's not to say they aren't worth doing, especially since they are not particularly difficult or time consuming once you've done a WCAG audit.

Steve Green
Managing Director
Test Partners Ltd

From: Jim Byrne Accessible Web Design
Date: Fri, Apr 04 2025 5:34AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
← Previous message | Next message →

Thanks Steve,

Re: VPAT
I’ve recently had more people talking to me about VPAT’s, so that, along with a bit of Google’ing - that made me think they are becoming 'de facto requirements’ for some types of organisations. I’ll take on-board what you are saying and modify that part. Thanks

Jim

> On 4 Apr 2025, at 11:31, Steve Green via WebAIM-Forum < = EMAIL ADDRESS REMOVED = > wrote:
>
> The EU has no jurisdiction outside the EU countries (although it doesn't seem to understand this) so there are limits to what they can do if your website does not conform with the EAA. For instance, they can't force you to attend court, and there is no chance our government would consider an extradition request.
>
> However, they can demand that you cease the provision of your services to the EU. They could even block traffic to your website from EU countries, although I expect they would only do this for very large organisations like Google and Amazon. And in theory, they might be able to arrest you if you set foot in an EU country, although I think this is extremely unlikely. Small and medium size organisations are likely to just go under the radar.
>
> It's worth noting that the EU regards the EAA as applying to EU citizens regardless of where they are in the world. If you provide a service to EU citizens but only outside the EU, then there really is nothing the EU can do to enforce their law.
>
> With regard to VPATs, I wouldn't say they are "a de facto requirement when selling digital products or services to public sector bodies". I have worked for some of these third parties, and I am in a UK government discussion group on accessibility, and VPATs are rarely mentioned. That's not to say they aren't worth doing, especially since they are not particularly difficult or time consuming once you've done a WCAG audit.
>
> Steve Green
> Managing Director
> Test Partners Ltd
>

From: Mosley, Leigh
Date: Fri, Apr 04 2025 6:17AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
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I think you could safely say that it has become common for large organizations in the US to expect a VPAT to be provided. Especially after last year's updates to the ADA law here.

Best,

Leigh Mosley, MA, MLS, CPWA
Accessibility Coordinator
University of Tennessee Libraries
1015 Volunteer Boulevard
Knoxville, TN 37996-1000
865-974-0011
= EMAIL ADDRESS REMOVED =

Schedule a meeting with me: https://calendly.com/leighmosley

From: Barry
Date: Sat, Apr 05 2025 6:04AM
Subject: Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses
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Here's one that hasn't been tested yet: Might the Windsor Protocol between the Republic of Ireland, which is in the EU, and Northern Ireland have a bearing on the UK's obligation to the EAA?

From: Steve Green
Date: Sun, Apr 06 2025 8:34AM
Subject: Re: Have I got all of these legal requirements and defacto requirement correct for private sector businesses
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I don't believe it has any bearing in practice. The Windsor Framework and Northern Ireland Protocol are all about product standards and customs borders for goods. Food and pharmaceutical standards are included, but my understanding is that most other standards are not. Services are excluded.

Steve Green
Managing Director
Test Partners Ltd