3 duties the Equality Act places on UK digital magazine publishers

What to take away

Equality Act magazine accessibility boils down to three duties: reasonable adjustments for disabled readers, avoiding discrimination in content and services, and accessible design and service provision.
The Equality Act 2010 applies to digital magazine publishers as service providers, not just as employers or landlords.
Reasonable adjustments can include accessible digital editions, alternative formats and staff training, and the duty is anticipatory.
Accessibility must be built into apps, EPUB, PDF and web editions, not bolted on after a complaint.
Testing and documenting decisions is your best evidence if a reader challenges you.
Data protection and consumer law overlap with accessibility, so join up your policies.

What the Equality Act 2010 requires of digital magazine publishers

The Equality Act 2010 is the main UK law protecting people from discrimination because of disability, among other protected characteristics. It applies across England, Scotland and Wales, with some differences in enforcement in Northern Ireland.

For digital magazine publishers, the Act matters in three ways. First, you have a duty to make reasonable adjustments for disabled readers. Second, you must not discriminate in the content or services you provide. Third, you must provide accessible design and service provision.

These are legal duties, and they apply whether you publish a paid app, a free web edition or a print title with a digital counterpart.

The Act is long, but the parts that matter most to publishers are in the service provider provisions. You can read the full Equality Act 2010 on the legislation website, but the practical points are simpler.

If you offer a service to the public, you must not treat disabled people less favourably and you must make reasonable adjustments. That includes the way you design, write and distribute your magazine.

Many publishers assume accessibility is only about websites. It is not. It covers apps, email newsletters, PDF downloads, EPUB files, audio versions and even the way you handle subscriptions and complaints. If a disabled reader cannot use your digital edition, you may be in breach of the Act.

Who counts as a service provider

A service provider is anyone who provides goods, facilities or services to the public, whether paid or free. Digital magazine publishers fit that description. You provide content, subscriptions, advertising and customer service. The service provider duties are set out in Part 3 of the Equality Act 2010.

This means a reader can bring a claim against you if they believe you have discriminated against them.

The size of your operation does not matter. A small independent title publishing a monthly PDF is covered, just as a large consumer magazine group is. The law does not exempt you because you are a startup or because your audience is niche.

What counts as disability

The Act defines disability as a physical or mental impairment that has a substantial and long-term adverse effect on a person's ability to carry out normal day-to-day activities. This includes visual impairments, hearing loss, mobility difficulties, learning disabilities, mental health conditions and long-term illnesses such as cancer or HIV. Some conditions are automatically treated as disabilities.

You do not need a medical diagnosis to know that some of your readers are disabled. The Office for National Statistics estimates that around one in five people in the UK report a disability. That is a significant part of your audience, and it includes people who develop impairments as they age.

The anticipatory nature of the duty

The reasonable adjustments duty is anticipatory. You cannot wait until a disabled reader complains and then fix the problem. You must think ahead about what disabled readers might need and take reasonable steps to meet those needs. This is different from some other areas of law, where you only have to react to a specific request.

In practice, this means you should review your digital editions regularly, test them with assistive technology, and have a plan for providing alternative formats. It also means training your editorial and production staff so they understand accessibility from the start. Learning how to build a magazine flatplan can help you build that into your workflow.

Duty one: reasonable adjustments for disabled readers

The reasonable adjustments duty is the first of the three main duties. It requires you to take reasonable steps to remove or reduce disadvantages that disabled readers face because of your practices, policies or physical features. For digital publishers, the adjustments are usually about how content is delivered and accessed.

What is reasonable depends on your size, resources and the nature of your service. A large publisher with a dedicated tech team may be expected to do more than a two-person operation. But even small publishers can make adjustments.

These might include offering an accessible digital edition, providing transcripts for audio, or ensuring that subscription forms work with screen readers.

Examples of reasonable adjustments

Reasonable adjustments for a digital magazine might include:

Providing an accessible digital edition that works with screen readers and keyboard navigation.
Offering alternative formats such as plain text, large print, or audio versions.
Ensuring that your website and app meet accessibility standards such as WCAG 2.2 at level AA.
Training customer service staff to handle accessibility requests.
Allowing subscribers to request a different format without extra charge.
Making sure that email newsletters are readable by assistive technology.
Providing captions and transcripts for video content.

This list is not exhaustive. The key is to think about the barriers disabled readers face and what you can reasonably do to remove them. If a reader asks for a specific adjustment, you should consider it seriously, even if it is not on your standard list.

The cost defence

Cost can be a factor in deciding what is reasonable. If an adjustment would be disproportionately expensive, you may not have to make it. But you cannot simply claim poverty.

You need to show that you have considered the adjustment and that the cost is genuinely disproportionate to the benefit. In practice, many accessibility adjustments are low cost or free, especially if you build them into your design process from the start.

For example, adding alt text to images costs nothing but time. Using accessible colour contrasts is a design choice. Providing a plain text version of an article can be automated. The expensive adjustments tend to be retrofitting accessibility to a legacy app or a complex interactive feature.

The link to service provider duties

The reasonable adjustments duty sits alongside the service provider duties. You can read the specific wording in section 20 of the Equality Act 2010. It sets out the three requirements: avoid disadvantage, remove or change a physical feature, and provide an auxiliary aid or service.

For digital publishers, the auxiliary aid might be a screen reader compatible file or a British Sign Language video for a subscriber tutorial.

The Scottish Government has a British Sign Language policy that shows how public bodies approach BSL. While that policy applies to Scottish public authorities, it is a useful example for publishers who want to provide BSL interpretation for video content. If you produce video magazines or tutorials, BSL interpretation can be a reasonable adjustment.

Duty two: avoiding discrimination in content and services

The second duty is to avoid discrimination in the content and services you provide. This covers direct discrimination, indirect discrimination, harassment and victimisation. For magazine publishers, this means you must not treat disabled readers less favourably because of their disability, and you must not apply policies that put disabled readers at a disadvantage.

Direct discrimination is when you treat someone worse because of a protected characteristic. For example, refusing to sell a subscription to a reader because they are blind, or charging them more for an accessible format, could be direct discrimination.

Indirect discrimination is when a policy or practice applies to everyone but disadvantages disabled people. For example, requiring all subscribers to use a particular app that is not accessible could be indirect discrimination.

Content that discriminates

Content itself can discriminate. If your magazine publishes articles that mock disabled people, or uses language that is derogatory, that can create a hostile environment. The Editors' Code of Practice, enforced by IPSO, requires publishers to avoid prejudicial or pejorative reference to a person's disability.

While the Code is not the same as the Equality Act, it reinforces the same principles.

You should also consider how you portray disability in your editorial. Avoid stereotypes, such as presenting disabled people as objects of pity or as inspirational solely because of their disability. Use person-first language where appropriate, and consult disabled writers and contributors.

Service delivery and customer service

Discrimination can happen in customer service too. If a disabled reader phones to ask for help and is treated rudely or refused assistance, that could be discrimination. Your staff should be trained to handle accessibility requests courteously and effectively. This includes knowing how to provide information in alternative formats and how to escalate requests that they cannot handle.

You should also review your subscription processes. If your sign-up form is not accessible, disabled readers may be unable to subscribe. That is a service delivery issue. Similarly, if your cancellation process is only available by phone and a deaf reader cannot use the phone, you may need to offer an alternative.

Advertising and sponsored content

Advertising and sponsored content are part of your service. If you accept an advert that is discriminatory, you could be held responsible. The Advertising Standards Authority (ASA) also has rules about offensive or harmful content. You should have a policy for reviewing adverts and sponsored content for accessibility and discrimination issues.

For example, an advert that uses a flashing animation could trigger seizures in readers with photosensitive epilepsy. An advert that is only available as an image without alt text is inaccessible to screen reader users. These are practical issues that you can address in your ad booking terms.

Duty three: accessible design and service provision

The third duty is to provide accessible design and service provision. This is closely linked to the reasonable adjustments duty, but it focuses on the design of your digital products and the way you deliver your service.

It means that accessibility should be built into your apps, websites, EPUB files and PDFs from the start, not added as an afterthought.

Accessible design benefits all readers, not just disabled ones. Clear navigation, readable text and consistent layouts help everyone. But for disabled readers, these features are essential. If your digital edition is not accessible, you may be excluding a significant portion of your potential audience.

What accessible design means in practice

Accessible design means following recognised standards and guidelines. The Web Content Accessibility Guidelines (WCAG) are the international standard for digital accessibility. WCAG 2.2 level AA is a common benchmark. It covers things like text alternatives for images, keyboard accessibility, sufficient colour contrast, and clear headings.

For digital magazines, accessible design also means:

Using semantic HTML in web editions so screen readers can move through the page.
Providing a logical reading order.
Ensuring that interactive elements are keyboard accessible.
Adding captions and transcripts for audio and video.
Making sure that PDFs are tagged and have a proper reading order.
Designing EPUB files with accessibility metadata and reflowable text.
Testing with assistive technology such as screen readers and voice control.

You can find more detail in our guide to building a flexible magazine layout system. It walks through the key checks for each format.

Service provision beyond the page

Service provision includes the whole reader experience. That means your website, your app, your customer service, your email communications and your social media. If any of these are inaccessible, you may be in breach of the duty.

For example, if your app requires a gesture that a reader with a motor impairment cannot perform, you need an alternative. If your email newsletter is not readable by a screen reader, you need to fix it.

You should also consider the accessibility of your events. If you run reader events or webinars, make sure the venue is accessible and that online events have captions. Provide information about accessibility on your website so readers know what to expect.

The role of procurement

If you use third-party platforms for your digital edition, you are still responsible for accessibility. You should ask suppliers about their accessibility features and include accessibility requirements in your contracts. If a supplier cannot meet your needs, consider switching. The law does not allow you to pass the buck entirely.

Applying the duties to apps, EPUB, PDF and web editions

Different formats have different accessibility challenges. The duties apply to all of them, but the practical steps vary. Here is a breakdown of what to consider for each format.

Format	Key accessibility considerations	Common pitfalls
Web editions	Semantic HTML, keyboard navigation, alt text, colour contrast, responsive design	Missing headings, low contrast, inaccessible forms
Apps (iOS/Android)	Screen reader compatibility, touch target size, captions, no reliance on gestures alone	Custom controls without labels, unlabelled buttons
EPUB	Reflowable text, proper metadata, logical reading order, alt text	Fixed layout without accessibility, missing language tags
PDF	Tagged PDF, reading order, alt text, accessible forms	Scanned images without OCR, untagged PDFs, security settings that block screen readers

Each format has its own quirks. For example, a PDF that looks fine visually may be completely inaccessible to a screen reader if it is not tagged. An EPUB that uses fixed layout may not reflow for readers who need larger text. An app that relies on complex gestures may be unusable for someone with a motor impairment.

Testing each format

The only way to know if your digital edition is accessible is to test it. You can start with automated tools, but they only catch some issues. Manual testing with assistive technology is essential. That means using a screen reader such as NVDA or VoiceOver, using only a keyboard, and checking colour contrast.

You should also test with disabled readers if possible. User testing with people who have different access needs will reveal problems that automated tools miss. Our guide to how to build a magazine workflow covers common issues and how to fix them.

A worked example

Imagine a fictional publisher, Riverside Review, that produces a monthly digital magazine via a PDF and a web edition. The PDF is created from InDesign and exported without tags. The web edition uses images for headlines and has low contrast text.

A disabled reader complains that they cannot read the magazine with their screen reader. Riverside Review investigates and finds that the PDF has no tags and the web edition has no alt text. They decide to:

Re-export the PDF with tags and a logical reading order.
Replace image-based headlines with real text in the web edition.
Increase colour contrast to meet WCAG AA.
Add alt text to all images.
Train staff on accessibility basics.

The publisher documents these changes and sets up a quarterly accessibility review. This shows how a publisher can respond to a complaint and meet the reasonable adjustments duty. You can read a fuller version in our guide to feature scene writing.

Testing accessibility and documenting your decisions

Testing is not a one-off task. You should build accessibility testing into your production cycle. That means testing new issues before publication, and re-testing when you update your platform or app. Documenting your decisions is also important. If a reader challenges you, you need to show that you have taken accessibility seriously.

A simple testing checklist

Here is a checklist you can use for each digital edition. It is not exhaustive, but it covers the basics.

All images have appropriate alt text.
Headings are used in a logical order.
Colour contrast meets WCAG 2.2 AA (4.5:1 for normal text).
The edition can be used with only a keyboard.
Screen reader testing has been done on at least one major screen reader.
Videos have captions and transcripts.
PDFs are tagged and have a logical reading order.
EPUB files have accessibility metadata and reflowable text.
Forms and interactive elements are labelled and usable.
There is a way for readers to request alternative formats.

You can adapt this checklist for your own workflow. The key is to make it routine. If you are building a new article, our comparison of magazine planning tools walks through the steps.

Documenting your decisions

Keep records of your accessibility testing and any adjustments you make. This can include test results, checklists, meeting notes and training records. If you receive a request for an adjustment, record what you did and why. This documentation can be useful if you need to show that you have met your duties.

You should also document any decisions not to make an adjustment, and the reasons. For example, if you decide that a particular feature is not reasonable because of cost, record the cost and the benefit. This shows that you have considered the matter.

Training and culture

Accessibility is not just a technical fix. It is a culture. Train your editorial, design and production staff so they understand why accessibility matters and how to achieve it. Include accessibility in your style guide and your commissioning briefs. Encourage staff to think about disabled readers from the start.

Where accessibility overlaps with data and consumer law

Accessibility does not exist in a vacuum. It overlaps with data protection and consumer law, and you should join up your policies. The Information Commissioner's Office (ICO) enforces data protection law. That includes rules about how you collect and use personal data.

If you collect accessibility information from readers, such as their preferred format, that is personal data. It may be special category data if it reveals a disability. You should only collect such data if you need it, and be clear about why you are collecting it and how you will use it.

You should also keep it secure. A breach of data protection law could compound an accessibility failure.

Consumer law and accessibility

Consumer law also matters. If you sell a digital subscription, you must comply with consumer protection rules. If your digital edition is not accessible, a disabled reader might argue that it is not fit for purpose.

The Consumer Rights Act 2015 implies terms into contracts for digital content, including that it must be of satisfactory quality and fit for purpose. Accessibility can be part of that.

You should also be clear about your terms and conditions. If you offer alternative formats, say so. If you charge extra for them, consider whether that is fair. Charging more for an accessible format could be discriminatory.

Working with regulators and industry bodies

The Professional Publishers Association (PPA) offers guidance and training on accessibility for its members. IPSO's Editors' Code of Practice includes provisions on discrimination. Ofcom regulates broadcast content but also has accessibility requirements for on-demand services. If you produce video content, you may need to comply with Ofcom's rules on subtitling and audio description.

You do not have to work through this alone. Industry bodies and accessibility consultants can help. But the legal duty remains with you as the publisher.

A final word on proactive compliance

Proactive compliance is cheaper and less stressful than reacting to complaints. Build accessibility into your workflows, test regularly, and document your decisions. That way, you can be confident that you are meeting your duties under the Equality Act 2010 and serving all your readers well.

Common questions

Does the Equality Act 2010 apply to small digital magazine publishers? Yes. The Act applies to all service providers, regardless of size. Even a one-person operation publishing a PDF magazine is covered. What is reasonable may vary with your resources, but the duty itself does not disappear.

What is a reasonable adjustment for a digital magazine? It depends on the barriers and your resources. Common adjustments include providing an accessible digital edition, offering alternative formats such as plain text or audio, ensuring your website works with screen readers, and training staff. The duty is anticipatory, so you should think ahead.

Do I need to make my PDF accessible? Yes, if you provide PDFs as part of your service. An accessible PDF is tagged, has a logical reading order, and includes alt text for images. Untagged PDFs are often unusable with screen readers. Testing with a screen reader will show you the problems.

Can I charge extra for an accessible format? Charging extra for an accessible format may be discriminatory. You should provide accessible formats at no additional cost where it is reasonable to do so. If there is a genuine additional cost, consider absorbing it or seeking funding.

What happens if a reader complains about accessibility? You should take the complaint seriously and investigate. Try to resolve it by making the adjustment. If the reader is not satisfied, they may take the matter further, including to court. Documenting your actions and decisions will help you respond.

How does accessibility relate to data protection? If you collect information about a reader's disability or accessibility needs, that is personal data and may be special category data under the UK GDPR. You must have a lawful basis, keep it secure, and only use it for the purpose you collected it. The ICO provides guidance.