The EAA accessibility statement: template, mandatory content and who must publish one
In short
An accessibility statement is a public document that reports how accessible a digital service is: its conformance status, the standard used, the content that is not yet accessible, and how to get help or complain. Under the European Accessibility Act (Directive (EU) 2019/882), service providers such as online stores must publish accessibility information about their service — an obligation that has applied since 28 June 2025.
- the widely used EU model expresses one of three conformance statuses: fully, partially or not compliant;
- a short accessibility notice with a link to the full statement usually sits in the footer of every page;
- a missing statement is the easiest breach to establish — an inspector does not need to audit dozens of technical criteria to note that the document is absent.
Making a site technically accessible is one obligation; documenting it is a separate one. The accessibility statement is the part a regulator can check in seconds — a page either exists or it does not. Here is what it must contain under the EAA, the recognised EU template, and how to produce it honestly rather than copying a boilerplate that overclaims.
What an accessibility statement is
It is a public page — distinct from your legal notice and your privacy policy — that accounts for the accessibility of your digital service. It answers a simple question for a user with a disability: "Can I use this site, and what do I do if I can't?" A complete statement names the standard the site was measured against, gives the result, lists what is not yet accessible, and provides a way to report a barrier and escalate.
The concept is not new to the EU. Public-sector bodies have published accessibility statements since the Web Accessibility Directive (EU) 2016/2102, for which the Commission adopted a model statement (Implementing Decision (EU) 2018/1523). The European Accessibility Act now extends an equivalent duty to private services such as e-commerce — and that public-sector model is the practical reference most businesses build on.
Where the obligation comes from
The European Accessibility Act is Directive (EU) 2019/882. It requires service providers to prepare information explaining how their service meets the accessibility requirements, and to make that information available to the public in an accessible way (Article 13 and Annex V). Because the EAA is a directive, each Member State has transposed it into its own national law — so the exact wording, and the enforcement details, are national. The substance of what you must disclose is common across the EU.
Who must publish one
Any organisation whose digital service falls under the EAA. Among the covered services, e-commerce is named explicitly — the sale of products or services to consumers through a website or app. Banking, electronic communications, e-books, passenger transport and audiovisual media services are also in scope.
The three conformance statuses (and why honesty protects you)
The EU model statement uses one of three normalised statuses, and only one:
| Status | Meaning |
|---|---|
| Fully compliant | Every requirement of the standard is met. In practice rarely achievable, and risky to declare without an exhaustive manual audit. |
| Partially compliant | Most requirements are met, with documented non-conformities. The honest, defensible status for most sites. |
| Not compliant | The site has not been assessed, or most requirements are not met. |
The standard you measure against: EN 301 549 / WCAG 2.1 AA
The EAA sets functional requirements rather than a line-by-line checklist. In practice, digital accessibility is assessed against the harmonised European standard EN 301 549, which for the web incorporates WCAG 2.1 level AA. Your statement should name the exact standard and version you tested against, and say how you tested — automated scan, manual audit, or both. Following the harmonised standards opens a presumption of conformity with the requirements.
The template: the mandatory sections
An accessibility statement built on the EU model contains at least the following:
- Conformance statusThe official status (fully / partially / not compliant) and the standard used (EN 301 549, incorporating WCAG 2.1 AA).
- Non-accessible contentThe list of known non-conformities, with — where relevant — content exempt as a disproportionate burden and content falling outside the scope of the law.
- Preparation of the statementThe date it was written, the method (automated audit, manual audit, or both), and the tools and environment used to test.
- Feedback and contactA way for a user to report an accessibility failure and request an alternative, plus the contact who handles it.
- Enforcement / recourseThe route a user can take if they get no satisfactory reply — the competent authority or complaints body in the country concerned.
Alongside the statement, a full programme also includes — depending on your situation — a remediation plan or roadmap showing that conformance is improving over time. The statement is a snapshot; the roadmap is the evidence that it is being kept true.
Where and how to publish it
- A dedicated page at a stable URL (for example
/accessibilityor/accessibility-statement). - A notice on every page — usually in the footer — stating the status and linking to the full statement.
- Content that is itself accessible: a statement published as an untagged PDF or an image unreadable by a screen reader would contradict its own purpose.
Enforcement is set country by country
There is no single EU-wide penalty. Each Member State designates its own supervisory authority and sets its own sanctions, so the regulator and the amounts depend on the market you are assessed in. A missing or inaccurate statement is one of the first things a routine check or a user complaint surfaces. A few examples covered in detail:
| Country | National law | Fine range (example) |
|---|---|---|
| Italy | D.Lgs. 82/2022 (authority: AgID) | €5,000 – €40,000 |
| Spain | Ley 11/2023 | see country guide |
| Germany | BFSG (Barrierefreiheitsstärkungsgesetz) | see country guide |
| Sweden | EAA transposition (in force) | up to SEK 10M |
An overlay does not produce your statement
"One-click" accessibility widgets (accessiBe, UserWay) do not generate the legally required statement, and do not establish the real conformance status of your site. They add a layer whose effectiveness is disputed by disability organisations; in the United States the FTC fined accessiBe one million dollars in 2025 over misleading compliance claims. The defensible path is the opposite: audit the site, fix what can be fixed, then declare honestly.
Get your ready-to-publish statement
DeclareAccess scans one page of your site (WCAG 2.1 AA), sends you a quantified report of the non-conformities, then generates your accessibility statement in the applicable template — English, French (RGAA), Italian, Spanish or German (BFSG) — with the exact conformance status, the non-accessible content and the routes of recourse. Free audit, no credit card.
WCAG report by email within 1 business day.
Got it. Your audit request is saved — you'll receive your WCAG report by email within 1 business day.
Frequently asked questions
Is an accessibility statement mandatory for a private company?
Yes. Under the European Accessibility Act (Directive (EU) 2019/882), service providers whose service is in scope — e-commerce, banking, e-books, electronic communications and more — must publish accessibility information about their service, an obligation in force since 28 June 2025. The main exception is micro-enterprises providing services (fewer than 10 people and turnover/balance sheet ≤ €2M), though most established stores exceed a threshold. Enforcement is set by each Member State.
Can I declare my site "fully compliant"?
Technically yes, but it is risky: full conformance assumes no requirement of the standard is in default, which is nearly unattainable and unverifiable without an exhaustive manual audit. The "partially compliant" status, with an honest list of the remaining non-conformities, is generally the defensible choice.
What is the difference between the accessibility notice and the statement?
The notice is the short status line ("Accessibility: partially compliant") shown on every page, usually in the footer, with a link. The statement is the detailed page that link points to: it contains the mandatory sections — conformance status, non-accessible content, how the statement was prepared, feedback and contact, and the enforcement/recourse route.
Is there an official EAA accessibility statement template?
The EAA itself sets the required information (Article 13 and Annex V) rather than a fixed form, and each Member State transposes it. The practical reference is the EU model statement from the public-sector Web Accessibility Directive (Implementing Decision (EU) 2018/1523), which uses the three conformance statuses. Some national transpositions prescribe specific content; publishing an accurate statement is safer than copying a boilerplate that overclaims full conformity.
Is an automated audit enough to write the statement?
It gives a factual, quantified baseline (contrast, image alternatives, structure, forms) and lets you write an honest "partially compliant" statement. It does not cover every criterion, so a manual audit is still needed for an exhaustive assessment — and the statement must describe exactly the method you used.