Every government digital service is told it must be accessible by law. The one time GDS checked in full depth, not a single website or app it tested passed.
Estimated reading time: 7 minutes
In short. The GOV.UK Service Manual tells every team building a government service that "your service must be accessible to everyone who needs it" and that "you may be breaking the law if you do not make your service accessible" [1], naming WCAG 2.2 level AA as the current minimum. The Government Digital Service's own monitoring report, the only one ever published, tested against the older WCAG 2.1 standard instead, for a period ending September 2024, and even so found that "none of the 52 websites" and "none of the 21 apps" it examined in full depth were fully compliant [2]. Three documented mistakes: four stars.
The duty is not new and it is not soft law. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 require every UK public sector website and app to meet the Web Content Accessibility Guidelines, and the Service Manual, GDS's own doctrine for every team building a government service, translates that duty into a plain instruction: "your service must be accessible to everyone who needs it," with WCAG 2.2 level AA as the floor, "as a minimum" [1]. The same page does not hedge on the consequence of getting it wrong: "you may be breaking the law if you do not make your service accessible" [1].
GDS is also the body that checks. Under the 2018 regulations, the Cabinet Office is required to monitor compliance, a job it delegates to GDS, and GDS publishes the results [3]. Its most recent report, covering monitoring between January 2022 and September 2024 and published 17 December 2024, is the only public, government-wide account of how well the law is actually being followed.
What the regulator's own numbers say
The report is candid about scale before it is candid about failure. GDS "monitored 1,203 websites and 21 mobile apps during this monitoring period," and states plainly that "accessibility issues were found on nearly all tested websites and apps" [2] (Executive summary). Most of that sample got the lighter "simplified" test, a small page sample checked mostly by automated tooling. Fifty-two websites and 21 apps got the full "detailed" test, checked against all 55 relevant WCAG success criteria with assistive technology. The report's own verdict on that harder group is unambiguous: "at the time of each detailed test, none of the 52 websites were fully compliant," and "at the time of each initial test, none of the 21 apps were fully compliant with the accessibility regulations" [2] (sections 4.3 and 4.4).
The overall totals are large. GDS "found 29,787 accessibility issues across monitored websites and apps," of which "16,482 (55.3%) were fixed by the public sector organisations during the monitoring," while "3,693 issues (12.4%) were not fixed when we retested the website or app" [2] (section 4.1). The rest were never confirmed either way: 8,596 of the simplified-test issues alone "were not retested at 12 weeks due to the page or site being removed or we received no response from the public sector organisation" [2] (section 4.2). The most common failures, colour contrast, missing keyboard focus indicators, keyboard traps and pages that break when resized or zoomed [2] (Executive summary), are exactly the barriers that stop someone using a screen reader, a screen magnifier or a keyboard alone from completing a government transaction at all.
A report built on a standard that is no longer current
The Service Manual's live text names WCAG 2.2 level AA as the minimum today [1]. The 2022-2024 report was not tested against it. GDS's own appendix says so directly: "for the period of this report, our testing was based on... WCAG version 2.1 levels A and AA. WCAG 2.2 was published on 5 October 2023 and became the legal technical standard for the accessibility regulations. Our team has been monitoring for this standard since October 2024" [2] (Appendix A). The report's monitoring window closed the same month WCAG 2.2 monitoring began. The regulations were amended in 2022, but the government "will still publish a report every 3 years for transparency," and this was "the second published report" [2] (Executive summary). No date is given for when a report against the standard actually in force today will appear. Almost three years after WCAG 2.2 became the legal technical standard, there is still no published government-wide account of how well the public sector meets it.
The enforcement step that is described but not shown happening
The regulations are not merely advisory. GDS passes every case, fixed or not, to the Equality and Human Rights Commission for England, Scotland and Wales, or the Equality Commission for Northern Ireland, "who are responsible for enforcement of equality and non-discrimination laws" [2] (section 2.6). The report describes a two-stage EHRC process, first a compliance letter, then, "if the organisation fails or refuses to comply," escalation to "a binding agreement to comply with the regulations, or... an investigation" [2] (section 9.3). What the report actually records, in its own account of the EHRC's work since the regulations took their current form, is the first stage only: "of the 93 public sector bodies in England and Wales that the EHRC has sent initial letters to since 1 January 2022, compliance was secured with 66, without the need for enforcement, with the remaining matters ongoing," and in Scotland, "compliance was secured with 2, and continue to engage with the remaining 3" of five [2] (section 9.3). No case is described, in Great Britain, where the second stage, an actual binding agreement or investigation, was used to close out a public body that did not respond to a letter.
The claims, tested
| The document's own words | What the record actually shows | Verdict |
|---|---|---|
| Service Manual: "Your service must be accessible to everyone who needs it. You may be breaking the law if you do not," WCAG 2.2 level AA "as a minimum," last updated 17 December 2025 [1] | GDS's own most recent, and only, government-wide compliance report tested against WCAG 2.1, not 2.2, for a period ending September 2024 [2] (Appendix A) | The mandate names the current legal minimum; the only public evidence of compliance is against the standard it replaced, with no date set for a report against the current one |
| Accessibility regulations require public sector websites and apps to meet WCAG, monitored by GDS on the Cabinet Office's behalf [3] | "None of the 52 websites" and "none of the 21 apps" tested in full depth were fully compliant, even against the older WCAG 2.1 bar [2] (sections 4.3, 4.4) | Where the government checked hardest, the pass rate against the easier standard was zero |
| The report describes a two-stage EHRC enforcement process ending in "a binding agreement... or... an investigation" for non-compliant bodies [2] (section 9.3) | Of 93 English and Welsh bodies sent a first-stage letter since 2022, 66 complied "without the need for enforcement"; the remaining 27, plus 3 of 5 in Scotland, are recorded only as "ongoing," with no completed second-stage case described [2] (section 9.3) | The backstop exists on paper; the report gives no example of it being used to a conclusion |
The mistakes, counted
The Service Manual's own current legal minimum has never been the subject of a published compliance report (1). WCAG 2.2 became "the legal technical standard for the accessibility regulations" on 5 October 2023, and GDS has "been monitoring for this standard since October 2024" [2] (Appendix A). The only report published tested the standard before it, for a period that ended the same month WCAG 2.2 monitoring began, and the next one is not due for years under the stated "every 3 years" cadence [2] (Executive summary).
Zero of the sites and apps checked in full depth passed, even against the easier standard (2). "None of the 52 websites were fully compliant" at detailed testing, and "none of the 21 apps were fully compliant" at initial testing [2] (sections 4.3, 4.4), against WCAG 2.1 rather than the current 2.2 standard the Service Manual now names. Of 29,787 issues logged across all testing, only 55.3% were confirmed fixed [2] (section 4.1).
The enforcement power the regulations rely on is described but never shown completing a case (3). The EHRC's account, reproduced in the same report, records 66 of 93 first-stage letters in England and Wales resolved "without the need for enforcement," with the remaining matters "ongoing" [2] (section 9.3). No binding agreement or completed investigation is cited anywhere in the report.
Credit where due
The monitoring itself works. Sending a report and giving an organisation 12 weeks to respond fixed 16,482 of 29,787 issues found, and the completion rate is improving: 68% of simplified-test cases had fixed their issues or had a credible plan by the 12-week mark, up from 59% in the previous monitoring period [2] (Executive summary). Accessibility statement publication rose from 85% to 97% of sites and apps once monitoring intervened [2] (section 5). Organisations that went through the process largely say it worked: "83% of organisations reported that it has helped them fix accessibility issues on their website" [2] (section 7). And the Service Manual does not leave teams to work it out alone: it points them to DWP's own Accessibility Manual, a detailed, role-by-role guide covering everyone from content designers to software engineers [4], a resource one government department chose to build and publish rather than keep to itself.
Verdict
Four stars, from three documented mistakes. The law is clear, GDS checks for it seriously, and the checking measurably fixes things. What the government's own report does not show is a public sector that meets its own current legal minimum, or a regulator that has ever had to use its full enforcement powers to make one comply. A government service telling its users, correctly, that it "must be accessible" is not the same claim as one that has been tested against the standard it names and passed.
Sources
- Making your service accessible: an introduction, GOV.UK Service Manual, Government Digital Service, first published 9 March 2016, last updated 17 December 2025
- Accessibility monitoring of public sector websites and mobile apps from 2022 to 2024, GOV.UK corporate report, Government Digital Service / Cabinet Office, published 17 December 2024
- The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, SI 2018/952, regulation 4
- Guidance for your job role, DWP Accessibility Manual, Department for Work and Pensions