WCAG 2.2 Compliance in the UK: Why £4,950 Accessibility Audits Are Blocking Quality (And What to Do About It)

£4,950 plus VAT for a single website accessibility audit.

For an agency managing 20 clients annually, that's £99,000 in audit costs alone—before fixing a single issue, before any remediation work, just for knowing whether your sites comply with WCAG 2.2.

Most accessibility checking gets skipped. Not proudly. Not deliberately. But practically. The economics don't work.

The October 2024 Deadline: One Year Enforced

WCAG 2.2 became the UK legal standard for accessibility in October 2024. Published 5 October 2023, it added 9 new success criteria compared to WCAG 2.1.

UK public sector monitoring began in October 2024. We're now one year into enforcement.

The GOV.UK accessibility monitoring report covering 2022-2024 demonstrates enforcement is real and effective:

• 16,482 accessibility issues fixed as direct result of PSBAR monitoring
• 1,203 websites and 21 mobile apps monitored
• Nearly all tested sites had accessibility issues
• 68% of organisations resolved problems or had plans to do so
• 55.3% of issues fixed during the monitoring period

Enforcement finds problems. Monitoring leads to remediation. The question isn't whether compliance matters—it's how agencies can afford to check for it.

The £4,950 Audit Cost Reality

AbilityNet—the UK's leading digital accessibility charity, recognised by UK government enforcement bodies—offers Digital Accessibility Reviews for £4,950 + VAT.

Scope: Homepage, navigation, header/footer plus up to 10 core components.

This isn't even a full-site audit. It's a representative sample audit from one of the UK's most respected accessibility providers.

Other UK providers confirm similar pricing:

• Jim Byrne (UK): £2,000 minimum (£2,500 with disabled testers)
• International providers: $1,500-$5,500 USD typical range
• WCAG 2.2 premium: Typically adds 10% to WCAG 2.1 audit costs

The pricing isn't unreasonable—it reflects the reality that comprehensive WCAG 2.2 testing requires manual expert review. Automated tools catch only part of the picture.

The Economic Impossibility

Let's do the uncomfortable maths:

Agency managing 20 clients:

• 20 sites × £4,950 = £99,000 annual audit cost (before VAT)
• With VAT: £118,800 total
• This is just for knowing compliance status, not fixing issues
• Would need repeating with major site changes

For most UK agencies, this is financially impossible.

What Actually Happens

Here's the real workflow for most agency projects:

1. Agency quotes client project at competitive rate
2. £4,950 accessibility audit not budgeted (would make project unprofitable)
3. Accessibility checking skipped or minimal (free tool spot-checks only)
4. Site launches with unknown accessibility compliance
5. Agency crosses fingers hoping no complaints or enforcement

When accessibility checking actually happens:

• Client specifically requests and budgets for accessibility audit
• High-profile project where legal risk is obvious
• After complaint or enforcement action (reactive, not proactive)
• Almost never as routine quality assurance

This isn't negligence. This is the practical reality when comprehensive audits cost more than many agencies charge for an entire website build.

Understanding Automated vs Manual Testing

Here's the reality: not all accessibility issues can be detected automatically.

UK Government Digital Service research found that best automated tools catch 30-40% of 142 known accessibility issues.

Traditional estimates suggest automated tools catch 20-30% of WCAG issues. Deque's updated research found 57.38% of total issue volume can be identified using automated tests (measuring issue volume, not criteria coverage).

The conclusion: 60-70% of accessibility issues require manual human testing with screen readers, keyboard navigation, and expert review.

WebAIM puts it plainly: "WAVE and other automated tools can only identify some accessibility issues. You should also test the page with a keyboard, screen reader, and/or browser developer tools."

The Choice: 30-40% Coverage vs 0% Coverage

Here's the reality:

Option A: £99,000 annual cost for comprehensive manual audits across all clients Result: Financially impossible for most agencies

Option B: £0 cost, skip accessibility checking entirely Result: Unknown compliance status, legal liability, reputational risk

Option C: £288/year for automated checking catching 30-40% of issues Result: Baseline compliance across all clients, strategic manual audit allocation

Which option represents responsible accessibility practice within budget constraints?

The Tiered Approach

GuardianScan enables a practical tiered approach to accessibility compliance:

Baseline for all sites: £24/month unlimited scans

• Catches 30-40% of accessibility issues automatically (per UK GDS research)
• WCAG 2.2 Level AA automated checks
• All clients get accessibility checking, not just those who budget for it
• Regular compliance monitoring, not point-in-time audit
• Professional PDF reports document checking performed

Strategic manual audits: £4,950 audits for critical projects

• High-profile projects with legal visibility
• Client-facing applications with diverse user base
• Final validation before high-stakes launches
• Projects where budget allows comprehensive testing

Result: Comprehensive accessibility programme within budget constraints

Cost Comparison

When to Invest in £4,950 Manual Audits

Manual accessibility audits provide value when strategically allocated:

• Critical projects: High-profile, high legal risk
• Complex interactions: Custom UI components, dynamic content
• Diverse user base: Public-facing applications
• Final validation: Post-automated-checking review of critical paths
• Specific accessibility budget: Client has allocated funds

The tiered approach means manual audit budgets go where they deliver most value, whilst automated checking provides baseline compliance across the entire client portfolio.

The European Accessibility Act Context

The European Accessibility Act became enforceable 28 June 2025—four months ago as of this article's publication.

UK business impact: Any UK business with EU customers must comply

Threshold: >10 staff and >€2 million (£1.7 million) annual turnover

Scope: E-commerce, banking, e-books, transport services, electronic communications

This creates additional compliance pressure beyond UK PSBAR for businesses serving EU markets, making cost-effective accessibility checking even more critical.

Honest ROI

The economics become clear when considering legal risk:

• Single Equality Act complaint or enforcement action: £10,000-50,000+
• Preventing one lawsuit justifies: 35-170 years of GuardianScan subscription
• Reputational cost: Accessibility complaints damage agency credibility
• Client retention: Professional accessibility checking demonstrates agency quality

The question isn't whether accessibility matters—it's how to achieve compliance within economic reality.

What GuardianScan Checks

WCAG 2.2 automated checks include:

• Colour contrast (text, UI components, graphical objects)
• Text alternatives for images and non-text content
• Keyboard accessibility (focus indicators, navigation)
• Form labels and instructions
• Heading structure and semantic HTML
• Link text clarity and context
• ARIA implementation patterns
• Language attributes
• Page titles and landmarks

Plus 40+ additional checks across performance, security, SEO, and modern standards.

The Economics Should Enable Quality, Not Block It

Comprehensive accessibility compliance is financially impossible for most agencies at current audit costs. Automated checking provides practical first-line defence whilst manual audits remain reserved for critical scenarios.

The alternative—skipping accessibility checking entirely because £4,950 audits aren't affordable—serves no one. Not agencies, not clients, and especially not disabled users who deserve accessible digital experiences.

Try GuardianScan free — WCAG 2.2 automated checking in 45 seconds. Baseline compliance for all your clients, strategic manual audits where they matter most.

---

Key Statistics

• £4,950 + VAT: AbilityNet UK accessibility audit cost
• £99,000: Annual cost for agency with 20 clients (before VAT)
• 30-40%: UK GDS research on automated accessibility tool coverage
• 16,482 issues fixed: Direct result of PSBAR monitoring (2022-2024)
• 68% of organisations: Resolved problems or had plans following monitoring
• October 2024: UK public sector WCAG 2.2 monitoring began (one year enforced)
• 28 June 2025: European Accessibility Act enforcement began

Resources

• GOV.UK: Accessibility Monitoring Report 2022-2024
• AbilityNet: Digital Accessibility Review Pricing
• GOV.UK Service Manual: Understanding WCAG 2.2
• European Accessibility Act: UK Business Impact

---

Catch 30-40% of accessibility issues automatically for £24/month. All your clients, all the time.