Gunning Principles and Accessibility: Why 20% Can’t Access Your Public Consultation

Introduction

Public consultations must be fair and inclusive, ensuring all participants can understand proposals and provide meaningful feedback. One of the well-known Gunning Principles for lawful consultation requires that sufficient information be provided to allow for “intelligent consideration and response”. In practice, when information isn’t readily accessible, whether due to format, language, or barriers related to disability, people may find it challenging to respond thoughtfully, which can undermine the entire process.

In the UK, public sector bodies have specific legal obligations: websites must meet WCAG 2.1 AA standards, and the Equality Act 2010 requires reasonable adjustments for disabled people. This article explores practical steps to design consultation materials and response routes that work across all platforms, so everyone can participate effectively.

Gunning Principle 2: “Intelligent Consideration and Response”

Gunning Principle 2 is one of four key criteria defining fair consultation in UK law. It requires authorities to provide enough detail and clarity about proposals so consultees understand the issues and can give informed feedback. Failing to do so by concealing key facts, using overly technical language, or releasing inaccessible documents can make a consultation unlawful.

Critically, “sufficient information” isn’t just about quantity; it’s about accessible content. A landmark 2014 Supreme Court case (Moseley) emphasised this point: consultees must be told about options and reasoning in a way they can grasp. Critically, “sufficient information” isn’t just about volume; it’s about accessible content. If a large portion of your audience cannot access or comprehend the material, you haven’t truly provided them with information. Gunning Principle 2, therefore, ties directly to accessibility: everyone must be able to understand and respond.

Why Accessibility Matters

Roughly one in five people in the UK has some form of disability, spanning visual, hearing, cognitive, and motor impairments. If consultation materials aren’t designed with these needs in mind, a significant portion of the public is effectively excluded. This isn’t just inequitable; it directly conflicts with Gunning Principle 2.

UK public bodies face clear legal obligations. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 require websites and apps to meet WCAG 2.1 AA standards. The Equality Act 2010 mandates reasonable adjustments, meaning consultation organisers must provide alternative formats (braille, large print, audio, Easy Read) and support where needed.

Designing for accessibility also improves the experience for everyone. Clear writing, logical structure, and user-friendly design benefit all users, helping consultees better understand proposals and respond intelligently.

Designing Accessible Consultation Materials

To meet Gunning Principle 2, consultation documents, webpages, and presentations must be easy to read, understand, and navigate:

Use plain language and clear design. Write in plain English, avoiding jargon. Aim for a reading level accessible to a broad public audience (typically ages 9-12). Short sentences, common words, clear headings, ample white space, and legible fonts help readers with cognitive or reading difficulties digest material.

Provide sufficient background and context. Don’t assume prior knowledge. Include brief background sections or FAQs explaining why the consultation is happening, what decisions are needed, and supporting evidence. For complex policies or infrastructure projects, add an executive summary or infographic. This ensures all readers, regardless of expertise, can form informed views.

Offer alternative formats. Not everyone can read standard documents or PDFs. Essential alternatives include:

• Large-print versions for people with visual impairments
• Braille or audio versions for blind or visually impaired individuals
• Easy Read versions for people with learning disabilities (using simple words, short sentences, and images)
• Translated materials where relevant (including British Sign Language videos)

Clearly state these formats are available and how to request them: “If you need this information in another format (large print, braille, or Easy Read), please contact [phone/email].”

Ensure digital accessibility (WCAG 2.1 AA compliance). Online consultations must be accessible to assistive technology users:

• Provide alt text for images, charts, and diagrams
• Ensure captions or transcripts for audio/video content
• Check colour contrast is sufficient and don’t convey information by colour alone
• Make websites fully keyboard navigable
• Ensure PDFs are tagged for accessibility, or provide HTML alternatives

Run accessibility testing before launch using automated checkers and, if possible, manual testing with screen readers.

Test with users or experts. Get feedback from people who experience barriers. Conduct quick user testing sessions or seek review from accessibility experts or local disability advocacy groups. Ask people with different needs (screen reader users, people with dyslexia, older adults) to review draft materials. This identifies pain points early and sends a message that you genuinely care about hearing from everyone.

Ensuring Accessible Response Methods

Making content accessible is only half the battle. People must also be able to respond through methods that work for them:

Provide multiple response channels. Offer more than one way to submit views. If the primary method is an online survey, also provide paper questionnaires, email addresses, and freephone telephone numbers. Millions of UK residents, particularly older adults, remain offline. Traditional methods like postal surveys or paper forms at libraries are invaluable. Public meetings or drop-in events accommodate those who prefer speaking rather than form-filling.

Offer assisted digital support. Provide help for those wanting to participate online but facing barriers. Set up telephone helplines where staff can guide people through online surveys or record their answers. Partner with libraries or community centres to offer in-person help. This ensures moving services online doesn’t leave people behind.

Make in-person events accessible. Choose wheelchair-accessible venues with hearing loop systems. Book BSL interpreters if needed. Use large, high-contrast text on slides and handouts. Train staff to assist-describing visual panels to blind visitors or simplifying explanations for those with learning difficulties. Explicitly mention accommodations in publicity.

Allow reasonable adjustments. Be flexible in collecting feedback. Accept responses by phone for those with visual impairments, or informal conversations for those with cognitive disabilities. Accept audio recordings or responses via advocates. Provide a clear contact point for requesting alternative arrangements.

Ensure assistive technology compatibility. Verify online survey platforms work with assistive technologies. All form fields should be properly labelled for screen readers, and interactive elements must work via keyboard. For advanced tools like interactive maps, provide alternatives such as text boxes or email submissions.

Conclusion

Accessible consultations aren’t just about legal compliance; they’re fundamental to fair process. Gunning Principle 2 requires people to have information they can actually access and understand. By integrating accessibility from the start (writing clearly, offering multiple engagement routes, removing barriers), public bodies ensure all stakeholders can participate.

The payoff is consultations that withstand scrutiny and produce better decisions. When more people engage effectively, feedback is richer and more informed, leading to outcomes accounting for diverse perspectives. Meeting Gunning Principle 2 in the modern era means meeting accessibility standards. Providing accessible information and supporting people to respond isn’t an extra task; it is the task of running a good consultation, ensuring every voice can be heard in public decisions.

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Whether you’re preparing for a high stakes service change, building long term consultation capability, or need confidence that your evidence approach will stand up to scrutiny, we can help.

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