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Guide · Building

"Schools Are Exempt" Is the Most Expensive Half-Truth in Education Web

By Measured 4 October 2026

The exemption is real, and it is much narrower than the people relying on it believe.

The short answer

Primary and secondary schools and nurseries are partially exempt from the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 — but the exemption does not cover content people need in order to use a service, and it does not remove the requirement to publish an accessibility statement. So a form a parent uses to set school meal preferences is in scope; so is anything else a parent must use to transact with the school. The technical standard is level AA of WCAG 2.2, the regulations have applied since 23 September 2018, and the Equality and Human Rights Commission enforces them. Separately and regardless, the Equality Act 2010 duty to make reasonable adjustments applies to the school whatever the regulations say.

What the exemption actually says

The regulations are the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. They came into force for public sector bodies on 23 September 2018 and the Equality and Human Rights Commission enforces them.

Primary and secondary schools and nurseries are partially exempt. That word does a great deal of work and it is routinely dropped.

The guidance states the exemption applies except for the content people need in order to use a service — and the example given is a form that lets you set school meal preferences. So the exemption is not about the school as an institution. It is about the difference between content a parent reads and content a parent has to use to get something done.

And partially exempt organisations still need to publish an accessibility statement on the website or app. That obligation survives the exemption entirely, which is the part most often missed: a school can be within the exemption for most of its content and still be non-compliant for having no statement.

What is in scope in practice

The test to apply to any page is: does a parent, pupil or applicant have to use this in order to get something done?

Things that are very hard to argue out of scope:

  • Any form — meal preferences, trip consent, absence reporting, parents' evening booking, admissions enquiries, free school meals applications.
  • A payment route, whether it is embedded or a link into a third-party system.
  • Login and account recovery for a parent portal.
  • The admissions process itself, where it is carried out on the site.
  • Anything a parent must read in order to complete one of the above.

A caution about the third-party point. Schools run a great deal of this through external providers — payments, parent apps, booking systems. Linking out to a supplier does not obviously put the journey outside your service, and in any case it does not help a parent who cannot use it. Ask suppliers for their accessibility statement and their WCAG conformance; a provider that cannot produce either is telling you something.

This is a web studio reading published guidance so you can see where it lands on a site. It is not legal advice, and whether a particular page is in or out of scope for your school is a question for the school and ultimately the EHRC, not for us.

The standard, and what it means on a real page

The technical standard is level AA of the Web Content Accessibility Guidelines, version 2.2, and the regulations frame the goal as making a site perceivable, operable, understandable and robust.

On a school website the failures are depressingly consistent, and most of them are cheap:

  • The newsletter and the term dates as scanned PDFs. A scan is an image; a screen reader gets nothing. This is the single commonest failure on school sites and it affects the documents parents need most.
  • Text over a photograph on the homepage banner, at a contrast ratio that fails.
  • Forms with no labels, or with the label as placeholder text that disappears the moment somebody types.
  • A navigation that cannot be operated by keyboard, usually because of a hover-only dropdown.
  • Images with no alt text, or with alt text reading "image1.jpg".
  • Tables used for layout, so a screen reader reads the page in an order nobody intended.
  • Video without captions, which has become much more common since schools started posting assemblies and open-day tours.

Almost none of that needs a new website. It needs the documents republished as HTML pages rather than scans, the contrast fixed, the forms labelled and the videos captioned. For most schools that is a programme of work measured in days, not a procurement.

The accessibility statement you have to publish anyway

Because this obligation survives the partial exemption, it is the one to deal with first — it is also the cheapest.

A statement is not a claim that everything is perfect. It is an honest account, and the honest version is more useful to a parent and more defensible than a boilerplate one. It should set out how accessible the site is, what is not accessible and why, what you are doing about it and by when, and how somebody reports a problem or requests content in another format.

That last part is the bit that actually serves people. A parent who cannot read the term dates needs a named route to get them another way, with a response time, not a general enquiries address.

Model statements exist — the Department for Education runs accessibility guidance for schools including a partially-compliant statement template, which is the right starting point for a school relying on the partial exemption. Work from a current template rather than copying another school's statement, which will describe their site and not yours.

The duty that applies regardless

Worth stating separately, because the exemption conversation tends to crowd it out.

The Equality Act 2010 places a duty on schools to make reasonable adjustments for disabled people. That duty is not created by the accessibility regulations and is not removed by the partial exemption from them. A parent who cannot access information because it is published only as a scanned image is a reasonable-adjustments question whatever the regulations say about the page.

Practically, this is why the "are we exempt?" framing is the wrong one to plan around. The useful question is whether a disabled parent can do the things the school needs parents to do. If the answer is no, the exemption is not much of a shield and it was never the point.

What to check on your own site

  • Is there an accessibility statement? This is required even under the partial exemption.
  • Does it say what is not accessible, what you are doing about it, and by when?
  • Does it give a named route to request content in another format, with a response time?
  • Are term dates, the newsletter and policies HTML pages, or scanned PDFs?
  • Can every form be completed with a keyboard alone?
  • Does every form field have a real label, not just placeholder text?
  • Can you reach every navigation item without a mouse?
  • Does the homepage banner text pass contrast against the photograph behind it?
  • Do your videos have captions?
  • Have your third-party providers — payments, parent app, booking — given you their accessibility statements?

The first three are an afternoon and they are the obligation that applies to you regardless. The fourth is the one parents will notice.

Sources

Everything this page relies on.

  1. Cabinet Office / Government Digital Service, "Understanding accessibility requirements for public sector bodies" — gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps, read 4 October 2026. Source for the full name and 23 September 2018 commencement of the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, the partial exemption for primary and secondary schools and nurseries, the exception for content people need in order to use a service (with the school meal preference form as the published example), the surviving requirement for partially exempt bodies to publish an accessibility statement, the WCAG 2.2 level AA standard, the perceivable/operable/understandable/robust framing, and EHRC enforcement.

  2. Department for Education accessibility guidance for schools, including the partially-compliant accessibility statement template — accessibility.education.gov.uk, read 4 October 2026.

  3. Equality Act 2010, reasonable adjustments duty — cited as a separate and continuing obligation, not as part of the accessibility regulations.

  4. This guide summarises published guidance for the purpose of website implementation and is not legal advice. Whether a particular page falls inside or outside the exemption is a matter for the school and ultimately the EHRC.

Common questions

Questions people actually search for.

Are schools exempt from the accessibility regulations?

Partially, not fully, and the difference matters. Primary and secondary schools and nurseries are partially exempt from the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 — except for the content people need in order to use a service, with a school meal preference form given as the example. And partially exempt organisations still have to publish an accessibility statement.

So what is actually in scope?

Apply the test: does somebody have to use this to get something done? Forms of any kind, payment routes, parent portal logins, the admissions process. Content a parent merely reads is where the exemption does most of its work; content a parent must use to transact is not.

Do we need an accessibility statement if we are exempt?

Yes. The requirement to publish a statement applies to partially exempt organisations too, which makes it the cheapest and most commonly missed obligation here. The Department for Education publishes a partially-compliant statement template, which is the right starting point.

What standard do we have to meet?

Level AA of WCAG version 2.2, with the regulations framing the goal as perceivable, operable, understandable and robust. In practice the common school failures are scanned PDFs, unlabelled forms, keyboard-inaccessible navigation, low-contrast banner text and uncaptioned video.

Our payments and parent app are third-party. Does that help?

Not obviously, and it certainly does not help the parent who cannot use it. Linking out does not clearly put the journey outside your service. Ask each supplier for their accessibility statement and WCAG conformance — a provider who cannot produce either has told you something useful.

Does the Equality Act still apply?

Yes, and it is independent of all of the above. The duty to make reasonable adjustments is not created by the accessibility regulations and is not removed by the partial exemption. That is why "are we exempt?" is the wrong planning question — the useful one is whether a disabled parent can do what the school needs parents to do.

Is your statement even there?

Send me your school’s website. I will tell you whether the accessibility statement exists and says anything useful, which documents are scans a screen reader cannot read, and which forms a parent could not complete with a keyboard.

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