3 duties the Equality Act places on UK digital magazine publishers

What to take away

The three duties on digital magazine publishers

Part 3 of the Equality Act 2010 covers goods, facilities and services, and its service provider provisions capture anyone selling content or subscriptions to the public. A free edition counts as a service.

Size does not exempt you: a two-person title publishing a monthly PDF is covered exactly as a large consumer group is. Disability is defined broadly, as a physical or mental impairment with a substantial, long-term adverse effect on daily activity.

Part 3 covers England, Scotland and Wales. Northern Ireland still runs on the Disability Discrimination Act 1995, and our Belfast magazine publishing guide sets out how that changes enforcement.

The duties are short to state. Remove disadvantage for disabled readers, avoid discrimination in what you publish, and design products people can use.

Duty one: reasonable adjustments for disabled readers

Section 20 sets the standard, and you can read the wording on reasonable adjustments in full. It requires three things: avoid the disadvantage, remove or change a physical feature, and provide an auxiliary aid or service.

For a publisher, the auxiliary aid matters most: a screen reader compatible file, a transcript or a captioned video.

Cost is a defence where an adjustment is genuinely disproportionate, but most fixes cost time rather than money.

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Examples of reasonable adjustments

Treat the list as a starting point for other requests.

Duty two: avoiding discrimination in content and services

Direct discrimination means treating a disabled reader worse because of disability, such as charging more for an accessible format.

Indirect discrimination covers neutral rules that land harder on disabled people. Requiring every subscriber to use one app that screen readers cannot operate is the obvious publisher example.

Content counts too. The Editors' Code, enforced by IPSO, forbids prejudicial or pejorative reference to disability. Our review of how IPSO rulings shape magazine editorial decisions shows how those complaints are judged.

Advertising sits inside your service. A flashing animation can trigger seizures in readers with photosensitive epilepsy, and an advert supplied only as an image blocks screen reader users. Add both checks to your booking terms.

Duty three: accessible design and service provision

The design duty overlaps with adjustments but points forward. Accessibility belongs in the build, not added after a complaint. WCAG 2.2 level AA is the working benchmark, covering text alternatives, keyboard operation, contrast and heading structure.

Private publishers fall outside the public sector accessibility regulations, yet WCAG remains the yardstick advisers and courts use. Reflow and semantic order make compliance cheaper than retrofitting a legacy app.

A heading structure a screen reader can follow also works as a better contents page. Assistive technology fails on small structural errors, not on taste. Skipped heading levels and vague link text break the reading order.

Our magazine design and typography guide covers the grid, type and contrast choices that decide whether a page reads cleanly at 200 percent zoom.

Accessibility by format: apps, EPUB, PDF and web

Untagged PDFs are the most frequent failure: without structure tags, a PDF can read as an empty page to a screen reader.

A testing checklist that produces evidence

Run every edition through the same sequence before it ships, and keep the results.

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That log is what you produce if a reader complains. The habit of dated evidence our fact-checking guide applies to features works here too.

Consequences, time limits and where claims are brought

There is no routine inspection regime. A disabled reader who believes you discriminated brings the claim, usually in the county court in England and Wales or the sheriff court in Scotland.

The time limit is six months from the act complained of, so a slow fix does not stop the clock. Remedies include damages for injury to feelings, a declaration and a recommendation to change practice.

A tagged PDF and a captioning routine are cheaper than a defended claim.

Common questions