A public sector body covered by the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 must publish an accessibility statement covering its websites and mobile apps, in the format of the government's model statement, and keep that statement under regular review.
The statement says whether the site is fully, partially or not compliant with WCAG 2.2 AA, which content is inaccessible and why, how to report a problem and where to go if the response is poor. The Government Digital Service reviews the accessibility statement as part of every monitoring test.
What must an accessibility statement contain?
An accessibility statement must, under regulation 8, be in an accessible format, published on the body's own website for a website, and explain "those parts of the content that are not accessible and the reasons why". It must also describe any accessible alternatives where appropriate, link to a contact form for reporting failures, and link to the enforcement procedure in Part 5 of the regulations.
The statement must also follow the model accessibility statement, which "contains mandatory wording". Read with the GOV.UK sample statement, it sets this structure.
| Part of the statement | What it has to say |
|---|---|
| Scope | Which site or app the statement covers. The sample marks this sentence "legally required and must not be changed". |
| Compliance status | Fully, partially or not compliant with WCAG 2.2 AA. Fully applies "only if all requirements of the technical specification are fully met without exceptions". |
| Non-accessible content | Each problem, grouped as non-compliance, disproportionate burden or out of scope; a non-compliance adds the failed WCAG criterion and a fix date. |
| Feedback and contact | How to report a problem or ask for content in another format. |
| Enforcement procedure | Fixed wording, with a link to either the Equality Advisory and Support Service or the Equality Commission for Northern Ireland. |
| Preparation | When the statement was prepared and how. The model says the method "should be an actual evaluation". |
GOV.UK's guide, "Make your website or app accessible and publish an accessibility statement", says to publish the statement "as an HTML page" in plain English. The model asks for a prominent link, "for example in a static header or footer".
Which public sector bodies need an accessibility statement?
Any public sector body inside the regulations needs an accessibility statement, and regulation 3 defines that as the State, regional or local authorities and bodies governed by public law. A council is a local authority within that definition.
Regulation 4 takes out public service broadcasters, and takes schools and nurseries out except for content "relating to essential online administrative functions". GOV.UK's guide to the requirements says partially exempt organisations still publish a statement. It also says "public sector intranets and extranets need to be accessible and publish an accessibility statement", while apps built for defined groups such as employees or students fall outside the regulations.
Outsourcing changes none of this. GOV.UK says: "You're legally responsible for your website meeting accessibility requirements, even if you've outsourced your website to a supplier."
A disproportionate burden claim needs an assessment first
Regulation 7 lets a body leave content unfixed where compliance "would impose a disproportionate burden", but the body "must perform an assessment" first. The statement then has to explain which parts of the requirement could not be met.
GOV.UK is clear that "you cannot take things like lack of time or knowledge into account in your assessment." GDS's monitoring guidance lists a factor for outsourced sites: "how long the third party supplier is contracted for". In its 2022 to 2024 monitoring report, GDS recorded that "organisations claim disproportionate burden without having carried out an assessment beforehand". A claim also leaves the duty to make reasonable adjustments in place.
Which WCAG version does GDS monitor against?
GDS has monitored public sector websites and apps against WCAG 2.2 AA since October 2024. GDS announced the date in January 2024, and its monitoring report later confirmed that testing from October 2024 "uses WCAG 2.2, which adds 6 new success criteria" at levels A and AA.
The regulations name no version: regulation 9 refers to the WCAG level A and AA success criteria "as amended from time to time". WCAG 2.2 became a W3C Recommendation on 5 October 2023, and the model statement dropped its references to WCAG 2.1 on 30 September 2024.
A fix made in a shared template carries to every page that uses it, which is the case for building accessibility into the platform.
What happens when GDS tests your site
The regulations place the monitoring duty on the Secretary of State under regulation 10, and GDS carries out the monitoring on a random sample of sites and apps. Its simplified test samples pages including the home and contact pages, using the Axe extension plus manual checks such as zoom up to 400%. It also checks the statement, which "must include all mandatory wording, list all known accessibility issues and be up to date".
GDS sends its report "to the contacts in the organisations' accessibility statements". The monitoring guidance then asks the body to acknowledge it within 7 days and fix the issues within 12 weeks, and says anything not fixed "should be included in your accessibility statement". If every known contact route fails for a month, GDS forwards the case to the equality bodies, who "decide whether any further action is required".
Statements also have their own statutory check. Under regulation 14, the Secretary of State can require information by notice, with 28 days to respond. A body that fails to show compliance with regulation 8 receives a determination, which it can ask to have reviewed within 28 days; if it stands, the body's name is published.
The 2022 to 2024 report, which tested against WCAG 2.1, found that 85% of sites and apps had published a statement when first tested. After monitoring, 97% had one and 65% included all the necessary information.
Who enforces the accessibility regulations?
The Equality and Human Rights Commission enforces the accessibility regulations for bodies in Great Britain, and the Equality Commission for Northern Ireland enforces them in Northern Ireland, under regulation 11. Regulation 12 treats a failure to meet the accessibility requirement as a failure to make a reasonable adjustment.
Users can report a failure to the body under regulation 13. In Great Britain the route GOV.UK describes runs from the body to the Equality Advisory and Support Service, which, as the EHRC explains, escalates complaints it cannot resolve to the Commission.
How often should an accessibility statement be reviewed?
An accessibility statement should be reviewed at least once a year and after any major change. Regulation 8 says only "regular review", and GOV.UK's guide fills in the interval: review it "when there are major changes and at least once a year". The sample adds that the review is needed "even if there have not been significant changes to the website".
GDS's report found statements unreviewed for 12 months, and noted that "statements often refer to future fixes for issues where the dates have now passed". A redesign or a move to a new platform is the clearest trigger, and the model recommends a fresh evaluation "following a substantial revision". A supplier change counts too: the sample ties one burden claim to the date "when the supplier contract is up for renewal".
Day-to-day publishing moves a statement out of date as well, because each PDF or page an editor adds can carry an issue the statement does not list, a cost of decentralised publishing. Running the evaluation itself is a separate job, covered in a later piece.
What to ask a supplier about keeping the statement true
A supplier's template change or platform move can make a statement wrong without anyone editing the statement page. Put these questions in the requirement.
- Ownership after a release: When you change a template, component or third-party widget, who updates the non-accessible content section, and how fast? A strong answer names a role and a release step. A weak one says the client owns the statement.
- Testing before launch: Will you test against WCAG 2.2 AA before a redesign goes live, so the compliance status and the preparation date are true on launch day?
- Third-party content: Which third-party content on our site do you develop or control for us, or do we pay for? GDS says third-party content a body has funded, developed or controls is that body's responsibility, so its known issues belong in the statement.
- A GDS report: If a monitoring report arrives, can you help us acknowledge it within 7 days and fix within 12 weeks, and does the contract cover that work?
- Burden evidence: Where we claim disproportionate burden, will you supply the cost figures, and when does the claim lapse against your contract term?
Warning signs include "we're WCAG compliant" with no version or date, an overlay offered as the fix, and a burden claim with no assessment behind it.
Axistwelve builds, hosts and runs websites and digital services for central government, arm's-length bodies, regulators and local authorities. If you want to check whether a statement still matches the site after a redesign or a change of supplier, our government services team is the place to start.
Before you sign off your next accessibility statement
- Check the compliance status against WCAG 2.2 AA, and remove any remaining references to WCAG 2.1.
- Compare the non-accessible content section with your latest test results, and replace any fix date that has passed with a real one.
- Confirm every disproportionate burden claim has a written assessment and an end date tied to the contract.
- Make sure the contact address in the statement reaches someone who will answer a GDS report within 7 days.
- Diary the next review for a year from now, and add a statement check to any redesign or supplier change.
Frequently asked questions
Is there an accessibility statement template?
GOV.UK publishes a model accessibility statement and a sample statement for a fictional public sector website. Some wording in both is legally required and must be kept. Everything in square brackets has to be replaced with your own details, because GDS found organisations "directly copying and pasting text from the sample statement template".
Can one accessibility statement cover several websites?
One accessibility statement can cover several domains. The GOV.UK sample says "you can have a single accessibility statement that covers multiple domains, or a separate statement for each domain or subdomain". The legally required scope sentence then has to name what the statement covers.
Where should a mobile app's accessibility statement go?
A mobile app's accessibility statement must be in an accessible format. Under regulation 8 it can sit on the body's website "or alongside other information available when downloading the mobile application".
