Does your agency website need to be accessible?

Section 29 of the Equality Act 2010 says a person “concerned with the provision of a service to the public or a section of the public” must not discriminate against someone who needs that service, and section 29(7) puts service providers under a duty to make reasonable adjustments. An estate or letting agency is a service provider, and its website is where much of that service now starts: the property search, the valuation request, the viewing booking, the landlord enquiry.

The Equality and Human Rights Commission’s new Code of Practice for services, public functions and associations removes any doubt. It came into force on 5 August 2026, replacing the 2011 code, and paragraph 3.6 says: “The obligation also applies to the provision of services on a website (section 29).” The same paragraph says the duties apply whether a service is free or paid for, so a free property search or instant valuation is covered as much as a paid instruction.

The code is not the law itself (only courts decide that), but it is a statutory code, approved and laid before Parliament, and a court must take into account any part of it that is relevant to a case.

One of the code’s own examples could have been written about an agency. A legal services provider’s website “has all its text embedded within graphics”, so people with a visual impairment cannot enlarge the text or use text to speech software. The code treats that as indirect disability discrimination unless the provider can justify it, and as a case for a reasonable adjustment.

Most agencies assume accessibility is something they deal with when a customer asks. For services, the law works the other way round. Schedule 2 of the Act says the duty is owed to “disabled persons generally”, not only to a particular person, and the 2026 code (paragraph 7.22) calls it anticipatory: providers “must proactively consider the barriers that disabled people could face” before an individual disabled person tries to use the service.

That matters for a website because a visitor who cannot use it rarely complains. They leave, and book a valuation with the agency whose site worked. The Department for Work and Pensions’ Family Resources Survey for 2024 to 2025 classed one in four people in the UK as disabled, 16.7 million people. Among disabled pensioners, 68% had a mobility impairment and 34% a dexterity impairment, which is worth remembering when a downsizing vendor is trying to tap a small button on a phone.

Two more rules from the Act apply directly:

• Information can be part of the adjustment. Section 20(6) says reasonable steps include making sure information “is provided in an accessible format”. Property details, brochures and material information are information.
• You cannot charge for it. Section 20(7) says a provider cannot make the disabled person pay any part of the cost of complying with the duty.

What is reasonable depends on the business. The code lists the provider’s “size and resources” and “the financial and other costs of making the adjustment” among the factors, and the Act does not require a step that would fundamentally change the nature of the service. A two branch independent is not held to what a national group can afford. But most website faults are cheap to avoid when the site is built and expensive to fix afterwards, which leaves little room to call them unreasonable.

The Equality Act does not say which technical standard a private website must meet. The only UK rules that name one are the Public Sector Bodies Accessibility Regulations, which GOV.UK says require public sector websites to meet “the Web Content Accessibility Guidelines (WCAG) 2.2 AA accessibility standard”. They do not apply to agencies. The same GOV.UK page adds that “all UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010”.

So WCAG 2.2 at level AA is the sensible target: it is W3C’s current standard, the government holds its own websites to it, and it gives you something to test against and put in writing. It has three levels, A, AA and AAA, and AA is the one public sector sites must meet. In plain terms, a few of its requirements are:

• Text alternatives for images that carry information (1.1.1).
• Contrast of at least 4.5 to 1 between normal text and its background (1.4.3).
• Text that can be enlarged to 200% without losing content or function (1.4.4).
• Everything usable from a keyboard (2.1.1), with the keyboard focus visible on screen (2.4.7).
• Tap targets of at least 24 by 24 CSS pixels, with some exceptions (2.5.8).
• Labels or instructions wherever someone has to enter information (3.3.2).
• Captions on prerecorded video (1.2.2).

WebAIM tests the home pages of the top million websites every year with an automated tool. Its 2026 report, from a February 2026 scan, found 95.9% of home pages had detected WCAG 2 failures, an average of 56.1 errors per page. Its 33,059 real estate home pages averaged 63.3, 12.9% above the overall average. The most common failures across all sites were low contrast text (83.9% of home pages), missing image descriptions (53.1%), missing form labels (51%), links with no text a screen reader can announce (46.3%), buttons with none (30.6%) and no page language set (13.5%). WebAIM says 96% of all detected errors fall into those six types, and that automated tools cannot catch every failure, so the real picture is worse.

Those faults map neatly onto the parts of an agency website that win business:

• Property photographs and floor plans. A listing of twenty unlabelled photos tells a screen reader user nothing. Room names and sizes belong in the text of the page, not only in a floor plan image.
• The valuation and enquiry forms. Unlabelled fields and placeholder text that vanishes on typing are the commonest form failures, and the valuation form is the page that matters most. Our guide to getting more valuation requests covers the rest of that page.
• Search filters and map search. Price and bedroom dropdowns, icon buttons and map pins often cannot be reached by keyboard or have no label.
• Grey text on photographs. Pale headlines over hero images are the low contrast failure in its most common form.
• Sliders and carousels. WebAIM found pages using popular carousel libraries averaged 67 to 74 errors, well above the 56.1 average.
• Brochures and material information as image PDFs. That is the code’s text in graphics example again; provide the same facts as text on the page.
• Video tours without captions.

You can see the worst problems yourself in half an hour. Put the mouse away and try to search for a property, open a listing and send a valuation request using only the Tab and Enter keys. Zoom the browser to 200%. Turn on your phone’s screen reader and listen to a property page. Run a free automated checker over the home page and a listing. Anything you cannot do, some of your visitors cannot do either.

For a lasting fix, accessibility has to be in the build rather than bolted on, because most failures sit in the templates every page shares. When you replace or redesign a website, ask for these in the contract:

• The standard, WCAG 2.2 AA, in writing, covering the property search, listings and forms as well as the home page.
• Testing by a person, with a keyboard and a screen reader, not only an automated score.
• Content rules for your team, so the image descriptions and headings you add later keep the site accessible.
• Your own feeds checked, since property data, photos and documents arrive from your CRM.

Accessibility belongs on the list of what an estate agent website should include, alongside the legal display rules. If you are planning a new site, how we design estate agent websites sets out how we work, and what it costs is on our pricing page.

• legislation.gov.uk: Equality Act 2010, section 29 (provision of services)
• legislation.gov.uk: Equality Act 2010, section 20 (duty to make adjustments)
• legislation.gov.uk: Equality Act 2010, schedule 2 (services and public functions: reasonable adjustments)
• GOV.UK: Equality Act 2010 Code of Practice for services, public functions and associations, 2026 (in force 5 August 2026)
• GOV.UK: Equality Act 2010 Code of Practice for services, public functions and associations, 2026 (full text)
• GOV.UK: Understanding accessibility requirements for public sector bodies
• W3C: Web Content Accessibility Guidelines (WCAG) 2.2
• WebAIM: The WebAIM Million, the 2026 report on the accessibility of the top 1,000,000 home pages
• DWP: Family Resources Survey, financial year 2024 to 2025

More guides for agency owners are on the guides page.