The AGAR accessibility question explained: Assertion 10
From 2025/26, the Annual Governance Statement in the AGAR has a tenth assertion, on IT and data management. Website accessibility is part of it. This guide explains what it says, what the Practitioners’ Guide expects, and what evidence is worth keeping.
In short
- Assertion 10 first appears on the AGAR for 2025/26 (the year ending 31 March 2026). It stays in the 2026 edition of the Practitioners’ Guide.
- To answer “yes”, the Practitioners’ Guide says websites must meet WCAG 2.2 AA and the 2018 accessibility regulations “(where applicable)”.
- At a minimum, every authority’s website must have an accessibility statement that is kept under regular review.
- The 2026 edition asks internal auditors to check that website accessibility has been tested at least once a year, and that the statement has been updated.
What the AGAR and Assertion 10 are
The Annual Governance and Accountability Return (AGAR) is the yearly return that smaller authorities in England, including parish and town councils, complete for their accounts and governance. Section 1 is the Annual Governance Statement: a series of statements that the council answers “yes” or “no”.
The rules for completing it are set out in the Practitioners’ Guide, published by the Smaller Authorities’ Proper Practices Panel. The 2025 edition added Assertion 10, “Digital and data compliance”, with the note that it “will not appear on the AGAR until 2025-26”. The 2026 edition, which applies to financial years starting on or after 1 April 2026, gives the wording of the assertion:
“We have put in place arrangements for the effective IT and data management in accordance with proper practices during the year under review.”
The council approves the whole Annual Governance Statement by resolution at a meeting, before it approves the accounts. The chair and the clerk then sign and date it and enter a minute reference (Practitioners’ Guide 2025, paragraph 1.55).
What you need for a “yes”
The Practitioners’ Guide lists the actions an authority needs to have taken “to warrant a positive response”. In summary:
| Paragraph | What it covers |
|---|---|
| 1.47 | A generic email account on an authority-owned domain, such as clerk@abcparishcouncil.gov.uk, instead of a Gmail or Outlook address |
| 1.48 | All smaller authorities (excluding parish meetings) must meet legal requirements for all existing websites, whatever domain they use |
| 1.49 | All websites must meet WCAG 2.2 AA and the 2018 accessibility regulations (where applicable) |
| 1.50 | Websites must include the documents required by the Freedom of Information Act 2000 and, where it applies, the Transparency Code for Smaller Authorities |
| 1.51 to 1.53 | Following UK GDPR and the Data Protection Act 2018 |
| 1.54 | An IT policy (excluding parish meetings) covering how clerks, members and staff use IT for authority business |
What it means for your website
Paragraph 1.49 links the AGAR to the accessibility rules that have applied to public sector websites since 2018. GOV.UK guidance says a website meets the legal requirements if it meets WCAG 2.2 AA and publishes an accessibility statement, although “there may be valid legal reasons for not meeting accessibility standards” (GOV.UK: Understanding accessibility requirements).
The guidance section of the Practitioners’ Guide (2025 edition, paragraph 5.123) adds two practical points:
- An authority “does not have to buy a new website to comply with accessibility law if it places a disproportionate burden on the authority”.
- “At a minimum all authorities’ websites must include an accessibility statement on their website and keep it under regular review.” The statement should include reasons for not meeting accessibility requirements, ways to get alternative copies of documents that are not accessible, and a point of contact.
In practice, the most common gap on small council websites is scanned agendas and minutes. Our guide on how to make parish council minutes accessible covers this step by step.
What internal auditors are asked to check
The 2026 edition of the Practitioners’ Guide includes an internal audit control objective on “digital and data compliance”. Among other things, it asks internal auditors to:
- make sure the authority has, as a minimum, a single generic email address on an authority-owned domain
- “check that website accessibility has been tested, at least annually, and that the accessibility statement has been updated as required”
- check when the authority last completed a data audit, and that it has an up-to-date IT policy and a data protection policy reviewed at least once a year
The 2026 edition applies to the year ending 31 March 2027, so a dated test record and a reviewed statement are worth having well before your 2026/27 internal audit.
If you cannot answer “yes”
The Practitioners’ Guide (2025, paragraph 1.6) says that if an authority cannot answer “yes” to an assertion, it needs to give the external auditor an explanation on a separate sheet, “describing how the authority will address the weaknesses identified”. These explanations must be published with the completed AGAR. For councils with a turnover of £25,000 or less, the Transparency Code also says negative responses should be “explained fully, including how any weaknesses will be addressed”.
An honest “no” with a clear plan may serve the council better than a “yes” it cannot back up. That is a decision for the council, and its auditors can advise.
Evidence worth keeping
The Practitioners’ Guide (paragraph 1.5) says an authority needs “appropriate evidence to support a ‘Yes’ answer to an assertion, for example, a reference in a set of formal minutes”. For the website part of Assertion 10, these are our suggestions, not official requirements:
- a dated record of your latest accessibility test: what was tested, how, and by whom
- your published accessibility statement, showing when it was prepared and last reviewed
- a minute recording that the council reviewed the statement, or the results of the test
- if you claim disproportionate burden, the written assessment behind it
- a list of documents you have replaced with accessible versions, and when
Our free accessibility statement generator produces a statement based on the GOV.UK model, including the testing and review dates.
A note on the status of the new requirements
Not everyone agrees on how binding every part of Assertion 10 is. For example, a November 2025 report to Llanfair Waterdine Parish Council (PDF) argues that the email and IT policy requirements are best practice rather than statutory “proper practices”, while accepting that councils still need to consider them to answer “yes”. The website accessibility duty is different, because it comes from the 2018 regulations themselves.
Sources
- Practitioners’ Guide 2025 (with addendum), Smaller Authorities’ Proper Practices Panel, via SAAA (PDF), paragraphs 1.5, 1.6, 1.47 to 1.55 and 5.123
- Practitioners’ Guide 2026 (2026/27 combined), via SAAA (PDF): wording of Assertion 10 and the internal audit control objective on digital and data compliance
- Understanding accessibility requirements for public sector bodies, GOV.UK
- Model accessibility statement, GOV.UK
- Transparency code for smaller authorities, GOV.UK
- Running an accessible and inclusive parish or town council website, Wiltshire Association of Local Councils, February 2026