Accessibility Quick Guide

The UK Equality Act 2010 consolidated several earlier anti-discrimination laws into a single framework. It prohibits discrimination based on a list of protected characteristics, with disability explicitly included, and covers both direct and indirect discrimination as well as discrimination arising from disability.

⚠️ The Equality Act distinguishes between direct discrimination (treating someone worse because of disability), indirect discrimination (a neutral policy that disadvantages disabled people), and discrimination arising from disability (treating someone badly because of something connected to their disability). These are three distinct legal tests, not one.

The ADA is a civil rights law that prohibits discrimination against people with disabilities across employment, public accommodations, transport, telecommunications, and state and local government services. It treats disability discrimination as comparable to discrimination on grounds of race, sex, or religion.

⚠️ The ADA does not include explicit technical standards for digital accessibility. Federal websites are covered by a separate law (Section 508). Private business websites are covered under the ADA's public accommodations title, but enforcement has largely happened through litigation rather than prescribed technical standards.

The Ontarians with Disabilities Act commits the Government of Ontario, and all sectors of Ontario society, to work toward a province where barriers for people with disabilities are identified, removed, and not re-created.

⚠️ The Ontarians with Disabilities Act of 2001 focused mainly on the public sector and was considered limited in scope. It was followed in 2005 by the Accessibility for Ontarians with Disabilities Act (AODA), which extended requirements to the broader private sector and set specific, enforceable accessibility standards. The two acts are related but distinct.

All EU member states have implemented the EU Employment Equality Directive, which prohibits disability discrimination in employment. Beyond employment, member states vary considerably — some prohibit disability discrimination broadly, some require reasonable accommodation, some do both, and some do neither.

⚠️ EU-level harmonisation of disability discrimination law is incomplete. Employment protections are consistent across member states because of the directive, but protections outside employment — in healthcare, education, housing — differ significantly from country to country.