Digital-by-default isn't the same as digital-only — and that distinction matters if it genuinely doesn't work for you.
A government department can steer you toward its online service, but it generally can't make that the only door in. Public sector websites and apps are legally required to meet accessibility standards under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018, and several services are specifically required to keep non-digital alternatives open. Where digital genuinely isn't workable for you — because of disability, lack of access, or another real barrier — you're entitled to push for another route, and in at least one confirmed case, a right of appeal exists if that's refused.
| Protection | What it covers |
|---|---|
| Accessibility Regulations 2018 | Public sector websites/apps must meet WCAG 2.2 AA standards, be perceivable, operable, understandable and robust, and publish an accessibility statement listing known gaps |
| NHS GP services | Practices must offer phone or in-person options alongside any online tool, not instead of it, so patients aren't digitally excluded |
| HMRC (established by tribunal case) | Where online filing isn't reasonably practicable, phone filing must be permitted, and paper filing where phone isn't practicable either — with a right of appeal to the First-tier Tribunal against a refusal |
| Equality Act 2010 | Service providers, including public bodies, must make reasonable adjustments for disabled users even where specific digital regulations don't apply |
The government's own research shows people who are digitally excluded are more likely to miss out financially and practically — the push toward "digital-by-default" services is meant to save time and money for most users, not to exclude those who genuinely can't use them. That's why accessibility regulation, reasonable-adjustment duties, and service-specific rules exist alongside the drive to go digital, rather than replacing it entirely.
What if I can't use a government service online at all? Contact the department directly and explain that using the online service isn't reasonably practicable for you, whether due to disability, lack of digital access, or another genuine barrier. Some services, like NHS GP registration, are required to provide phone or in-person alternatives alongside any online tool, not instead of it.
Is there a legal right to appeal if a department refuses to let me apply offline? It depends on the specific service and department. In at least one confirmed case involving HMRC, a taxpayer who could not reasonably file online successfully established a right to file by phone or paper, with a right of appeal to the First-tier Tribunal against a refusal to permit alternatives to online filing.
Use Kibbo's Public Services & Administration tools to check your right to an alternative channel and draft your request.
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