Everyone should be able to use the thing you have built. That was always the argument. Since 28 June 2025 it has also been the law in more places than it used to be, and enforcement has stopped being theoretical.
Two approaches get talked about interchangeably and shouldn't be: accessible design and universal design. The difference matters, because one of them is a legal floor and the other is a design philosophy.
The European Accessibility Act became applicable on 28 June 2025. It applies to any business selling covered digital services to consumers in the EU, wherever that business is based. A UK company with a checkout an EU resident can reach is in scope.
Enforcement has followed. The first lawsuits were filed in France in November 2025. The Dutch regulator has been actively pursuing violations. Germany issued a fine of €150,000 over missing alternative text in a checkout. Penalties are set by each member state and range from roughly €60,000 in Ireland to €900,000 in Sweden.
There is one piece of breathing room: service contracts concluded before 28 June 2025 have until 28 June 2027. If you are running a legacy system under an older agreement, that is your deadline rather than a reprieve.
In the UK, the Equality Act 2010 has always required reasonable adjustments. It does not name a WCAG version — it asks whether disabled users are placed at a substantial disadvantage, and Level AA is the practical benchmark against which that gets judged. Public sector bodies are separately bound by the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018.
This is a summary, not legal advice. If you sell into the EU, confirm your specific obligations with a solicitor rather than relying on any published guide — including this one.
WCAG 2.2 has been the W3C recommendation since October 2023. Published guidance still conflicts over whether UK obligations point at 2.1 or 2.2, which is not a helpful position for anyone trying to budget.
Our advice is to build to WCAG 2.2 Level AA and stop worrying about it. Everything that passes 2.2 passes 2.1, and it means you are not re-doing the work when the underlying European standard catches up.
Accessible design focuses on making sure people with disabilities can use your site. It removes barriers for users with visual, auditory, cognitive or motor impairments, and it is measured against a standard.
Universal design is broader and starts earlier. Rather than accommodating specific needs after the fact, it aims to produce one interface that works well for the widest possible range of people — disabled or not.
Captions help people in noisy offices. Good contrast helps people in sunlight. Keyboard navigation helps power users. Most of what makes a site accessible makes it better for everyone, which is why universal design tends to pay for itself in ways an audit does not capture.
They are not alternatives, and treating them as a choice is how organisations end up doing neither properly.
Universal design is what you do at the start of a project, because building inclusive templates and components costs a fraction of retrofitting a live site under time pressure. Accessible design — audit, remediate, verify — is what you do to something that already exists, and it is what produces the evidence you can hand to a regulator or a procurement team.
Start with universal principles. Audit against the standard. Do both.
Automated tools are useful and they are not enough. Scanners are good at the mechanical failures — missing alt text, contrast ratios, absent language attributes — and those make up a minority of the problems that genuinely stop someone.
The failures that matter tend to be keyboard traps, form fields with no programmatic association to their labels or error messages, and focus management in single-page applications, where the content changes but a screen reader user is never told. None of those reliably show up in a scan. All of them will stop someone completing a loan application or a ticket purchase.
That is why our audits pair automated sweeps with manual testing of real user journeys, using screen readers, voice control, keyboard-only navigation and magnification.
Accessible design addresses the needs of users with disabilities against a measurable standard. Universal design aims for one experience that works for everyone from the outset. You want both, and since June 2025 the first one has teeth.
If you are not sure where you stand, an audit will tell you what is broken, who it excludes and what it takes to fix — with no obligation to have us do the fixing.
Talk to us about an accessibility audit.
