# Do the accessibility regulations cover your student app? URL: https://varsio.co.uk/blog/accessibility-rules-for-student-apps Updated: 2026-11-11 Blog # Do the accessibility regulations cover your student app? GOV.UK says apps for a defined group such as students fall outside the 2018 regulations. Why the Equality Act still applies, and what to ask a supplier for. By [Hasseeb Hussain](https://varsio.co.uk/authors/hasseeb-hussain) Published 11 November 2026 3 min read - Accessibility - Regulation Probably not, on GOV.UK’s reading of them: its guidance says that “mobile apps for specific defined groups like employees or students are not covered by the regulations”. The Equality Act 2010 still applies to a university app, though, so the sensible standard is the same one the regulations point to, WCAG 2.2 AA. ## What the 2018 regulations cover The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to the websites and mobile apps of public sector bodies. For mobile apps, regulation 5 applies them “after 22nd June 2021”. Regulation 3 defines a mobile application as software “designed and developed by or on behalf of a public sector body for use by the general public”. That phrase is where GOV.UK’s exclusion comes from: an app made for your students is for a defined group, not the general public. GOV.UK’s guidance sets the standard as WCAG 2.2 AA and asks for an accessibility statement. Regulation 8 says an app’s statement must be in an accessible format and available on the body’s website or “alongside other information available when downloading the mobile application”. ## Is a university a public sector body? The regulations count “bodies governed by public law”. Regulation 3 defines one as a body set up to meet needs in the general interest, not industrial or commercial, with legal personality, and either “financed, for the most part, by the State” or other public bodies, supervised by them, or with more than half of its board appointed by them. GOV.UK’s guidance does not name universities either way. Its monitoring does sample domains “such as .gov.uk, .ac.uk and .nhs.uk”, so university websites are in scope of the checks. Whether your university counts is a question for your own legal team. ## The Equality Act still applies In England, Wales and Scotland, section 91 of the Equality Act 2010 says a university must not discriminate against a student “in the way it affords the student access to a benefit, facility or service”, and it carries a duty to make reasonable adjustments. Section 20 adds that where the adjustment is about information, the reasonable steps include “ensuring that in the circumstances concerned the information is provided in an accessible format”. An app that a disabled student cannot use with a screen reader puts that student at a disadvantage in reaching university information and services, whichever way the 2018 regulations fall. ## Outsourcing does not move the duty GOV.UK is plain about websites: “You’re legally responsible for your website meeting accessibility requirements, even if you’ve outsourced your website to a supplier.” The regulations exempt third-party content only where it is “neither funded nor developed by, nor under the control of” the public body, which is hard to say of an app you pay a supplier to build in your name. The Equality Act duty is yours whoever builds the app. ## What to ask a supplier for - **WCAG 2.2 AA for the app itself,** not only for the supplier’s website. - **Evidence:** the results of testing with VoiceOver on iPhone and TalkBack on Android, and of automated checks. - **An accessibility statement for the app,** following regulation 8’s model: what is not yet accessible, the alternatives, how to report a problem, and how to escalate it. Even if the regulations do not require it for a student app, it tells students where they stand. - **A route for fixes:** who you contact when a student reports a problem, and how quickly it is fixed. ## What Varsio commits to Before it launches at your university, the Varsio app will be built to WCAG 2.2 AA and tested with VoiceOver and TalkBack. [Is the Varsio app accessible?](https://varsio.co.uk/answers/is-the-varsio-app-accessible) has the detail. ## Sources 1. [The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018](https://www.legislation.gov.uk/uksi/2018/952), legislation.gov.uk. Read 11 November 2026. 2. [Understanding accessibility requirements for public sector bodies](https://www.gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps), GOV.UK. Read 11 November 2026. 3. [Public sector website and mobile application accessibility monitoring](https://www.gov.uk/guidance/public-sector-website-and-mobile-application-accessibility-monitoring), GOV.UK. Read 11 November 2026. 4. [Equality Act 2010, section 91](https://www.legislation.gov.uk/ukpga/2010/15/section/91), legislation.gov.uk. Read 11 November 2026. 5. [Equality Act 2010, section 20](https://www.legislation.gov.uk/ukpga/2010/15/section/20), legislation.gov.uk. Read 11 November 2026.