Accessible agendas and minutes

The accessibility regulations catch every parish council in England. There is no small-council exemption, no turnover threshold, and no exception for a council whose website is maintained by a volunteer.

This guide covers what that means for the documents you publish most: agendas and minutes.

England; general guidance rather than legal advice.

You are in scope, whatever your size

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to public sector bodies, and a parish or town council is a local authority and therefore in scope.

There is no analogue to the £25,000 transparency threshold here. A council with a part-time clerk and a £15,000 precept is in scope on exactly the same terms as a county council. The exemption people sometimes reach for - for non-governmental organisations - is aimed at charities, and a parish council is a statutory local authority, so it can't apply.

Size does enter, but only through the disproportionate burden provision in regulation 7, which is a qualified defence, not an exemption, and it requires you to:

• perform an assessment - "A public sector body must perform an assessment of the extent to which compliance … imposes a disproportionate burden";
• take account of "the size, resources and nature of the public sector body" and the costs against the benefits to disabled people;
• say so in your accessibility statement, explaining which parts you haven't complied with; and
• where appropriate, provide accessible alternatives on request.

An unwritten assumption that it's all too much is not a disproportionate burden assessment.

What the regulations actually require

The duty is short: your website must be "perceivable, operable, understandable and robust". That's it. The regulations name no version of any standard.

What they give you is a presumption. Since 26 October 2022, regulation 9 has read:

"A website or mobile application of a public sector body will be presumed to be in conformity with the accessibility requirement to the extent that the website or mobile application conforms to Level A and AA Success Criteria as set out in the Web Content Accessibility Guidelines recommended by the World Wide Web Consortium, as amended from time to time."

Two things follow that are worth understanding.

The reference is dynamic. No version number, no date - it tracks whatever the W3C currently recommends. The older wording, which referred to EN 301 549 and the harmonised European standards, was replaced in 2022, so guidance still citing EN 301 549 is describing the pre-2022 law.

It is a presumption, not the duty. Meeting WCAG gives you the benefit of the doubt. The enforceable obligation is still the four-word standard, which is why passing an automated checker isn't proof of compliance.

Three dates that get conflated

If you have seen "WCAG 2.2 applies from September 2024" - including in otherwise reliable sector guidance - the month is wrong. The monitoring change was October 2024, and nothing in the law changed in either month.

So: aim at WCAG 2.2 AA. That's what the government reads the dynamic reference as meaning, and what your site will be monitored against.

Where your agendas and minutes stand

Anything published from 23 September 2018 must be accessible

Regulation 4(2)(a) exempts "office file formats published before 23rd September 2018" - and "office file formats" expressly includes PDFs and Word documents.

The trigger is the date of publication, not the date of the document. Minutes from 2012 that you upload in 2026 are published in 2026 and are in scope. This is the point clerks most often get backwards, and it has a sharp edge: if your archived minutes are re-uploaded during a website migration, the natural reading is that they are published afresh on that date and lose the exemption.

There is no general "PDFs don't count" rule. Every document published on or after 23 September 2018 is in scope.

The pre-2018 exemption is lost if the document is still in use

Regulation 4(2)(a) ends: "unless such content is needed for active administrative processes relating to the tasks performed by the public sector body". Government guidance glosses that as documents "users need … to use a service".

For meeting papers that usually works in your favour - historic minutes are a record, not an active process. But an allotment tenancy form, a burial fees sheet or a current policy that residents have to use is active, however old it is, and must be accessible.

Do not rely on an "archive" page

There is an exemption for archives, and it does not do what people hope. It applies to the content of "websites and mobile applications qualifying as archives", and an archive means a website that contains nothing needed for active administrative processes and hasn't been updated since 23 September 2019.

The unit is the whole website, not a section of it. Putting scanned minutes in an "Archive" page of your live, regularly updated site doesn't qualify - and no functioning council website can satisfy both limbs. A separately hosted, genuinely frozen archive site could, but that's a real decision, not a label.

Scanned minutes: the actual problem

A scan of a signed paper copy is a picture. There is no text layer, so a screen reader finds nothing to read, and no amount of good intent changes that.

The fix is to separate two things that councils tend to conflate:

• The signed paper record, which is what paragraph 41 of Schedule 12 requires and what you keep in the minute book.
• The published version, which needs to be readable by machines.

Publish structured HTML, or a properly tagged PDF generated from the source document rather than scanned from paper, and keep the signed scan as the internal record. If somebody genuinely needs to see the signature, they can inspect the minute book - which they have a statutory right to do anyway if they're an elector.

What "accessible" means for a document like an agenda

• Real headings, in order, rather than bold text that looks like a heading.
• Real lists and real tables, with header cells marked as header cells.
• Meaningful link text - not "click here".
• Alt text on any image that carries information; a decorative crest needs none.
• Adequate colour contrast, and never colour alone to carry meaning (a "confidential" item marked only by red text is invisible to some readers).
• Numbering that is part of the document structure, not typed in by hand.

Most of this is free if the document is generated rather than laid out by eye.

Your accessibility statement

You need one, and its form is prescribed: regulation 8(1) requires it to be provided "in accordance with the model accessibility statement" and kept "under regular review", and regulation 8(2) requires it to be published on the website in an accessible format. So it is not a free-text page.

If you're claiming an exemption - pre-2018 documents, or disproportionate burden - the statement is where you say so. Government guidance is explicit that claiming an exemption still requires you to explain it there. Silence is not compliance.

A statement that says everything is fine when the minutes are scanned images is worse than one that says: here is what isn't accessible, here is why, here is how to ask for an alternative format.

Who checks

The Government Digital Service monitors public sector websites and publishes findings. In practice the more likely prompt for a parish council is a resident's complaint, or a request for an accessible version - which you must be able to answer.

The route that avoids most of this

Almost every problem above comes from producing meeting papers as documents and then uploading pictures of them. In CouncilPapers, agendas and minutes are published as structured web pages - real headings, real lists, real numbering - alongside the PDF, so the published record is accessible by construction rather than by retrofit. See the accessibility statement, or book a demo.

Related: what a parish council must publish.

Last reviewed 26 September 2026. General guidance for councils in England, not legal advice.