Public sector websites have always had a moral and legal responsibility to ensures their websites are accessible to people with disabilities. The private sector/charities sometimes think they are exempt because....Read more

Digital Accessibility (Agenda Edition 6) 

Your website & disability discrimination – are you morally and legal compliant?  Are you sure? 


Public sector websites have always had a moral and legal responsibility to ensures their websites are accessible to people with disabilities. The private sector/charities sometimes think they are exempt because they are not specifically mentioned in the law, but disability discrimination rights do not discriminate. If landlords’ digital solutions like websites and apps prevent or restrict people from accessing services, they are discriminating. Prosecution can be an outcome, and in Social housing this is not a position anyone wants to be in.  Many big brands (including Dominos etc) have not taken this seriously and been successfully sued in high profile cases in other part of the world.

However, last September (2020) there was a deadline to act under a new regulation called Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

So, who is impacted?  Certainly, Local Authorities. What about Housing Associations/charities/3rd sector? They are not Public Sector, but these new regulations say ‘If you receive public sector funding’ you should now have an accessibility audit (or done one yourself) and are required to have an accessibility statement on your digital platform (such as your website). It covers not only websites, but tenant/customer facing apps too.

Yes - it’s a legal requirement, but for TPAS Cymru and the housing sector it’s more than that. We believe we simply must do better for the tenants and communities we support.

Did you know?

General UK stats says that 20% of the UK population have a form of disability. This rises to 30% over retirement age.  However, when you look at social housing in Wales, 39% of social tenants report that their day-to-day activities are ‘limited due to a long-term health problem or disability’ (Census, 2011).  Most people (83%) acquire their impairment rather than being disabled from birth.

Welsh Government has more detailed data on the ‘number of people who will struggle with domestic tasks’. We’re not going to list them all here, but instead, pose a question - if a noticeable part of the social housing population struggle with domestic tasks, how do they think they will get on with the website and digital channels of most landlords.  Are you feeling confident?

Questions for Tenant groups to ask:

Note: We were assisted by a friendly expert at 

1. Has your landlord done an accessibility Audit?  When was that?  Has there been an agreed statement added to that website/app?

2. How was the audit/testing done? Was it in-house? Was it done by the website/app provider?  Or did you work with an expert accessibility agency (like

3. What qualification/expertise did the person doing the accessibility audit have?  Are they independent?  Consider; will your website/app provider really deliver a critical accessibility audit after they were paid good money to develop the website in the first place!

3. Did the Audit rely on automated testing tools? This is a fool’s errand and will give poor audit results. For example, automated products will look at whether an image has an “alt” attribute, and give a Yes/No answer, but it cannot confirm if it’s actually correct and therefore compliant.  i.e.  you could have an image on your website giving details of a special offer with a discount, but a screen-reader only sees the alt tag as “image 5”. It would pass automated testing but would still be discrimination as the visually impaired user would have been excluded due to the misleading alt attribute.  (I reported a well-known brand in the past for something similar!)

4. Does the website rely on third-party tools to fix things? A plugin can make your site accessible. You need to fix things yourself, but first you need to understand the issues. That's why you'll need to start with an audit.

5. Are you confident your Accessibility Statement conforms to best practice?   (In case of interest there is a UK Government resource setting out templates for accessibility statements where you can see where your gaps are).

6. If you have gaps, failings, or areas to improve, have you published a commitment/roadmap with a timeline of when you think you'll be able to rectify these?

I hope these 6 questions will enable you to start a conversation about accessibility in this digital world we are living in.  Let me know how you get on and if you have any questions or feedback, contact  [email protected]

A BIG thank you:    This edition of The Agenda was made possible by re-writing/re-purposing a developer focused article written by Grant Broome, Digital Inclusion Strategist at DigInclusion that inspired me.  I am grateful to Grant for giving me permission for reshaping his expertise into this support material for tenants.

Need Digital Accessibility Advice, Support or an Audit?

DigInclusion are one the Europe’s leading authorities on digital accessibility. They advise a number of well-known household brands (see below). 
Grant himself is based in south Wales and is well known to TPAS Cymru and is highly respected in his field. Get in touch if your organisation needs support or an independent accessibility audit [email protected]