The 2002 list
Regulation 6 applies to anyone providing an information society service — which in practice means anyone selling or promoting commercially online. The standard it sets for accessibility is specific and worth quoting: the information must be available "easily, directly and permanently".
- The name of the service provider.
- The geographic address at which the service provider is established.
- Contact details, including an email address, that make it possible to contact them rapidly and communicate directly and effectively.
- Where registered in a trade or similar public register, the register and the registration number or equivalent.
- Where the activity is subject to an authorisation scheme, the particulars of the relevant supervisory authority.
- For a regulated profession: the professional body with which the provider is registered, the professional title and the member state where it was granted, and a reference to the applicable professional rules and how to access them.
- The VAT number, where the provider is subject to VAT.
Regulation 6(2) adds the pricing rule: where prices are referred to, they "shall be indicated clearly and unambiguously" and must say whether they are inclusive of tax and delivery costs.
And if you are a limited company
A second set of requirements applies on top. The Companies (Trading Disclosures) Regulations 2008 require every company to disclose particulars on "its business letters; its order forms; and its websites" — websites are named expressly rather than inferred.
- The part of the United Kingdom in which the company is registered.
- The company’s registered number.
- The address of its registered office.
- Where a limited company is exempt from using "limited" in its name, the fact that it is a limited company.
The registered office address and the trading address are frequently different, and the requirement is for the registered one. A site showing only the unit the business actually works from has not met it.
What a compliant footer actually looks like
Taken together, the practical answer for most limited companies is a few lines in the footer, present on every page — which is what "permanently accessible" is asking for.
- The trading name and the registered company name, where they differ.
- Registered in England and Wales (or Scotland, or Northern Ireland), company number 12345678.
- Registered office: the full address.
- VAT registration number, if registered.
- An email address, and ideally a telephone number.
- For a regulated business, the regulator, the registration number and a link to the applicable rules.
A sole trader without a company number still needs the name, the geographic address and the contact details. "Geographic address" means a real one — a business operating from home can usually use a correspondence address, but an email form alone is not an address.
The five ways sites get this wrong
- No address anywhere. The commonest failure by a distance, usually from a reluctance to publish a home address — which is a solvable problem rather than a reason to omit it.
- A contact form instead of an email address. The regulation asks for details allowing rapid, direct and effective communication; a form the business may or may not monitor is a weaker thing than an address.
- Company details on the About page only. "Permanently accessible" points at the footer, on every page, rather than one page a visitor may never open.
- Trading address shown, registered office not. They are different requirements and frequently different places.
- Prices without saying whether VAT is included. Regulation 6(2) is explicit, and it is the detail most often lost in a redesign.
None of this is expensive to fix and all of it is cheaper to fix before somebody asks. It is also, incidentally, a trust signal: a site that names the company, the number and the address reads as a real business, and a site that hides all three reads as what it looks like.
