Equality Act 2010 damages: Vento bands for websites

There are no Equality Act fines for websites. Tribunals award damages. The Vento bands set the typical range. When people ask what the "fine" is for an inaccessible website under UK law, the framing already contains a misunderstanding. The Equality Act 2010 does not work through regulatory fines. There is no Equality Act equivalent of the ICO's monetary penalty notices or the EU EAA's administrative sanctions. What the Equality Act provides is a civil remedy. A disabled claimant who has been discriminated against can bring a claim in the county court and receive damages.

For a technical audit of your site's accessibility, run a free scan at /uk/en/scan before a claimant does it manually.

Vento bands at a glance

The table below shows the approximate Vento band ranges for 2025/2026 as set out in the Presidential Guidance published at judiciary.uk. Verify current figures before relying on them. The bands are reviewed annually in April.

<div className="my-6 overflow-x-auto"> <table className="w-full border-collapse text-sm"> <thead> <tr className="border-b-2 border-slate-300 bg-slate-50"> <th className="px-3 py-2 text-left font-semibold">Band</th> <th className="px-3 py-2 text-left font-semibold">Range (£)</th> <th className="px-3 py-2 text-left font-semibold">Typical case</th> <th className="px-3 py-2 text-left font-semibold">Accessibility example</th> </tr> </thead> <tbody> <tr className="border-b border-slate-200"> <td className="px-3 py-2 font-semibold">Lower</td> <td className="px-3 py-2">£1,200 to £11,700</td> <td className="px-3 py-2">Less serious, isolated incidents</td> <td className="px-3 py-2">Single barrier on a website with limited impact</td> </tr> <tr className="border-b border-slate-200"> <td className="px-3 py-2 font-semibold">Middle</td> <td className="px-3 py-2">£11,700 to £35,200</td> <td className="px-3 py-2">Serious cases below the most grave</td> <td className="px-3 py-2">Sustained inaccessibility blocking important services</td> </tr> <tr className="border-b border-slate-200"> <td className="px-3 py-2 font-semibold">Upper</td> <td className="px-3 py-2">£35,200 to £58,700</td> <td className="px-3 py-2">Serious, prolonged or deliberate</td> <td className="px-3 py-2">Repeated refusal to remedy after complaint</td> </tr> <tr> <td className="px-3 py-2 font-semibold">Exceptional</td> <td className="px-3 py-2">Above £58,700</td> <td className="px-3 py-2">Exceptional gravity</td> <td className="px-3 py-2">Rare in single-claimant accessibility cases</td> </tr> </tbody> </table> </div>

The structure of Equality Act damages

Under section 119 of the Equality Act 2010, a county court that finds unlawful discrimination in services can award three categories of remedy.

Injury to feelings compensates for the distress, humiliation and frustration of being discriminated against. This is the central head of damages in most accessibility claims. It is calibrated to the Vento bands.

Actual financial loss compensates for any money the claimant lost as a direct result of the discrimination. In an accessibility context, this might include the cost of using an alternative service. It might include time costs in finding and using that alternative. It might include transport costs to visit a physical location instead of the inaccessible website. It might include charges incurred because an online-only discount was not accessible.

Aggravated damages are available where the respondent's conduct was high-handed, malicious or involved a dismissive response to the complaint. In practice, these are awarded where the organisation continued to discriminate after becoming aware of the issue. They are also awarded where it behaved dismissively to the claimant's initial contact.

The court can also make a declaration that the respondent has unlawfully discriminated. It can issue an injunction requiring specific remediation steps. Injunctions are more common in employment cases.

Vento bands explained

The Vento bands originate from Vento v Chief Constable of West Yorkshire Police [2002] EWCA Civ 1871. In that case the Court of Appeal established three bands for injury to feelings awards in discrimination cases. The bands apply to employment tribunal claims but are applied by analogy in county court service-provision cases.

Presidential Guidance on the bands is updated annually and published at judiciary.uk. For 2025/2026 the approximate figures are:

Lower band: approximately £1,200 to £11,700. These are less serious cases. They include isolated incidents with limited impact. An accessibility complaint about a single barrier on a website would typically fall here unless there were aggravating factors.

Middle band: approximately £11,700 to £35,200. These are serious cases but not the most grave. A sustained period of inaccessibility might fall here. A case where the barrier prevented significant use of important services might fall here too.

Upper band: approximately £35,200 to £58,700. These are serious, prolonged and exceptional cases. They include deliberate or especially damaging discrimination.

Cases of exceptional gravity can exceed the upper band. Verify the current Presidential Guidance figures before relying on these numbers. The bands are adjusted annually, typically in April. The Vento guidance is titled Presidential Guidance on Employment Tribunals: Vento Bands and can be found in the Resources section of the judiciary.uk website. County courts apply the same bands by analogy in service-provision claims under the Equality Act 2010.

The Judicial College Guidelines for General Damages in Personal Injury Cases, also referenced through the judiciary.uk website, are occasionally cited in accessibility claims involving consequential personal injury from the stress of inaccessibility. This is rare.

The claim path from complaint to award

Most accessibility cases never reach a hearing. The diagram below shows the typical route with rough timeframes per step.

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  <rect x="160" y="50" width="120" height="60" rx="6" fill="#f1f5f9" stroke="#475569" />
  <text x="220" y="74" textAnchor="middle" fontWeight="600">Pre-action</text>
  <text x="220" y="90" textAnchor="middle">letter</text>
  <text x="220" y="104" textAnchor="middle">1 to 3 months</text>

  <rect x="310" y="50" width="120" height="60" rx="6" fill="#f1f5f9" stroke="#475569" />
  <text x="370" y="74" textAnchor="middle" fontWeight="600">Negotiation</text>
  <text x="370" y="90" textAnchor="middle">or fix</text>
  <text x="370" y="104" textAnchor="middle">1 to 6 months</text>

  <rect x="460" y="10" width="140" height="60" rx="6" fill="#dcfce7" stroke="#16a34a" />
  <text x="530" y="34" textAnchor="middle" fontWeight="600">Settlement</text>
  <text x="530" y="50" textAnchor="middle">Most cases end here</text>
  <text x="530" y="64" textAnchor="middle">£2k to £15k typical</text>

  <rect x="460" y="90" width="140" height="60" rx="6" fill="#fef3c7" stroke="#d97706" />
  <text x="530" y="114" textAnchor="middle" fontWeight="600">County court</text>
  <text x="530" y="130" textAnchor="middle">claim filed</text>
  <text x="530" y="144" textAnchor="middle">12 to 18 months</text>

  <rect x="620" y="90" width="130" height="60" rx="6" fill="#e0e7ff" stroke="#4338ca" />
  <text x="685" y="114" textAnchor="middle" fontWeight="600">Hearing</text>
  <text x="685" y="130" textAnchor="middle">and award</text>
  <text x="685" y="144" textAnchor="middle">Vento + losses</text>

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  <line x1="280" y1="80" x2="308" y2="80" stroke="#475569" strokeWidth="1.5" markerEnd="url(#vb-arrow)" />
  <line x1="430" y1="70" x2="458" y2="45" stroke="#16a34a" strokeWidth="1.5" markerEnd="url(#vb-arrow)" />
  <line x1="430" y1="90" x2="458" y2="115" stroke="#d97706" strokeWidth="1.5" markerEnd="url(#vb-arrow)" />
  <line x1="600" y1="120" x2="618" y2="120" stroke="#475569" strokeWidth="1.5" markerEnd="url(#vb-arrow)" />

  <text x="380" y="200" textAnchor="middle" fontSize="11" fill="#64748b">Figures are typical. Actual outcomes vary with facts and conduct.</text>
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Typical award ranges in accessibility claims

Published county court judgments in EA 2010 accessibility claims are sparse. The large majority of cases settle before judgment. From the cases that have produced public decisions and settlement disclosures, the pattern is clear. Simple, single-barrier claims against SMB service providers tend to settle in the lower Vento band range. That is roughly £1,500 to £8,000 for injury to feelings plus any actual financial losses.

Claims involving sustained inaccessibility move into the middle band. So do claims with a claimant who has significant dependence on the service. So do claims with dismissive responses from the respondent. Claims involving large organisations with documented awareness of the issues are more likely to attract higher awards.

The practical implication is that financial exposure from a single accessibility claim at SMB level is most commonly £2,000 to £15,000 including costs. This is before considering the claimant's legal costs if the case is lost. These amounts are in a range that most businesses would prefer to resolve through remediation and settlement rather than litigation.

Why most cases settle

The settlement dynamic in Equality Act accessibility claims reflects several factors.

For claimants, bringing a county court claim requires instructing a solicitor. It requires paying a court fee. It requires managing a litigation process that may take 12 to 18 months to reach judgment. Disability rights solicitors often take these cases on conditional fee arrangements. The process is still demanding on the claimant.

For respondents, the risk of adverse publicity is often more significant than the damages exposure. Media coverage of a disability discrimination claim against a business is reputationally damaging regardless of the outcome. Settling quickly, fixing the website and making a goodwill payment avoids both the publicity and the ongoing legal costs of contested litigation.

Most accessibility-related EA 2010 disputes follow a pattern. A disabled user contacts the business. The user explains they cannot use the website. The business gives an inadequate or dismissive response. The user instructs a solicitor. A pre-action letter is sent. The business fixes the site and pays a settlement. The litigation itself is rarely necessary for either party to reach this outcome. The credible threat of it is what drives resolution.

How this compares to EU EAA enforcement

Under the EU Accessibility Act, national regulators in EU member states can impose administrative fines directly on non-compliant organisations. France, Germany and the Netherlands have all set fine bands in national legislation implementing the Directive. These are regulatory penalties rather than civil damages. They can be imposed without a disabled individual claimant.

The UK Equality Act 2010 has no administrative penalty mechanism. The EHRC can bring enforcement action and seek court orders under the Equality Act 2006. It does so strategically for systemic failures rather than routinely fining individual businesses. For individual claims, a claimant is required.

This structural difference means that UK website accessibility enforcement depends more on individual disabled users having the knowledge, resources and determination to bring claims. UK businesses face lower probability of regulator-initiated enforcement than their EU counterparts subject to the EAA. The individual claim risk is real. The reputational consequences are identical.

What happens when an EHRC investigation follows

Individual claims are the most common enforcement route. The Equality and Human Rights Commission has separate powers under the Equality Act 2006 to conduct formal investigations and issue unlawful-act notices. An EHRC investigation does not require a single claimant. The EHRC can act where it has reason to believe an organisation has committed unlawful acts affecting multiple people.

For website accessibility, an EHRC investigation is most likely where a pattern of complaints exists against a large organisation. It is also likely where the EHRC has identified a sector where inaccessibility is widespread and is running a strategic enforcement campaign. The EHRC's current enforcement priorities are published on its website and are updated periodically.

An unlawful-act notice under section 21 of the Equality Act 2006 requires the organisation to submit an action plan for eliminating the unlawful practice. The notice can be enforced in court if the organisation fails to comply. The EHRC can also accept binding agreements in lieu of formal proceedings. These function similarly to the ICO's undertakings.

The combination of individual claim risk and EHRC investigation risk creates a compound enforcement picture. A business that receives an individual accessibility complaint and fails to act on it faces higher risk on both dimensions. The claimant has a stronger case. The EHRC has more reason to be interested.

The anticipatory duty and why documented audits matter

One feature of the Equality Act that distinguishes it from purely complaint-driven regimes is the anticipatory duty under section 20. The obligation to make reasonable adjustments arises before any individual has complained. A court can find a breach even where no disabled user has yet brought a claim.

This means the relevant question is not "has anyone complained?" but "what adjustments would a reasonable organisation in your position have made?" Documented accessibility audits demonstrate that reasonable steps were taken. So do remediation plans. So does evidence that the organisation has been progressively improving its accessibility. An organisation with no accessibility audit history, no remediation record and no accessibility statement is in a weaker evidential position than one that has made documented, ongoing efforts. This holds true even if the website is not yet fully compliant.

For how accessibility statements fit into this picture, see accessibility statement template for UK businesses. For the EHRC investigation process in more detail, see EHRC investigations of websites.

For how the Equality Act 2010 applies to private websites generally, see website accessibility under the Equality Act 2010.

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This is technical analysis, not legal advice. Consult a solicitor for specific guidance on Equality Act claims and damages.