Accessibility is not optional on UK government digital services. It is built into the GDS Service Standard, required under the Public Sector Bodies Accessibility Regulations 2018, and underpinned by the Equality Act 2010. If you are hiring a contractor to work on a government digital service — or you are a contractor being asked to deliver accessibility work in that context — here is what that work looks like.
The GDS Service Standard and accessibility
The Government Digital Service Service Standard includes several points that require accessibility to be addressed throughout the delivery lifecycle, not just at the end.
Point 5, “Make sure everyone can use the service,” is the most direct. It requires teams to:
- Test with disabled users during user research
- Meet WCAG 2.1 AA as a minimum
- Publish an accessibility statement
- Fix accessibility issues raised during testing
Accessibility is also relevant to points 9 (create a secure service), 13 (use and contribute to open standards), and throughout the cross-government design system which has its own accessibility-first component library.
What accessibility contractors typically do on government digital projects
Roles vary by project phase. In discovery and alpha, the work is mostly upstream: requirements analysis, identifying which user groups need to be in research, reviewing early design concepts before they become expensive to change.
In beta, it shifts to integrated sprint reviews, testing design system components, and running an audit before the beta public assessment. Government service assessments include accessibility questions, and teams that have not done the work in beta tend to scramble at that point.
On live services, the main tasks are annual WCAG audits, keeping the accessibility statement current, and triaging user-reported barriers. There is also work that cuts across all phases: training developers and designers, reviewing supplier products for procurement, and producing VPATs for government software purchasing.
WCAG 2.1 versus WCAG 2.2 on government services
The 2018 regulations reference WCAG 2.1 AA. However, WCAG 2.2 was published in October 2023 and adds four new success criteria relevant to mobile and touch interfaces. Government digital teams are increasingly expected to address 2.2 criteria even where the regulations have not yet been updated.
If you are a contractor being asked about WCAG 2.2 readiness, the key new criteria to know are:
- 2.5.7 Dragging Movements
- 2.5.8 Target Size (Minimum)
- 3.2.6 Consistent Help
- 3.3.7 Redundant Entry
- 3.3.8 Accessible Authentication
IR35 and government digital contracts
Government contracts, particularly via Crown Commercial Service frameworks, fall under the off-payroll working rules. Medium and large public bodies must assess IR35 status themselves.
Many government digital accessibility roles will be assessed as inside IR35 given the degree of control, substitution limitations, and integration into the team.
If you are hiring outside IR35 for accessibility work, a fixed-scope audit or review deliverable is much easier to defend than an embedded “consultant” role that looks like a disguised employment.
I have experience working across UK government digital teams and can discuss contract structures that work cleanly for your procurement process. Get in touch.