What an EAA accessibility statement must contain

What the Directive requires

Article 13(2) of the Directive says: "Service providers shall prepare the necessary information in accordance with Annex V and shall explain how the services meet the applicable accessibility requirements. The information shall be made available to the public in written and oral format, including in a manner which is accessible to persons with disabilities. Service providers shall keep that information for as long as the service is in operation."

Annex V says the information goes "in the general terms and conditions, or equivalent document", must "describe the applicable requirements", and, where applicable, contain:

1. a general description of the service in accessible formats;
2. descriptions and explanations necessary for the understanding of the operation of the service;
3. a description of how the relevant accessibility requirements set out in Annex I are met by the service.

The provider may rely on the harmonised standards (in practice EN 301 549) to meet this, and must also provide information showing that its service delivery process and monitoring keep the service compliant (Annex V).

Two neighbouring duties matter for the statement too. Under Article 13(3) and (4) you need procedures that keep the service conformant as it changes, and if the service does not conform you must fix it and inform the competent national authorities. Under Article 14, if you rely on the fundamental alteration or disproportionate burden exception, you must document the assessment, keep it for five years, renew it at least every five years for services, and hand it over on request.

What Germany adds

Germany's Section 14 BFSG requires the information to be published in an accessible form, in the terms and conditions or otherwise clearly perceivable. Anlage 3 lists what it must contain, on top of the usual consumer information:

1. a general description of the service in an accessible format;
2. the explanations needed to understand how the service is carried out;
3. a description of how the service meets the relevant accessibility requirements;
4. the name of the competent market surveillance authority. For online shops that is the MLBF.

A German statement without the authority's name is incomplete.

Other national notes

• Italy. Large private companies covered by the older Legge Stanca regime use AgID's official model declaration from its guidelines for private entities. It is the closest thing to an official template we found for private businesses.
• Netherlands. If you rely on the disproportionate burden or fundamental alteration exception for a webshop, you must also notify ACM (ACM).
• Language. Publish the information in the languages your shop sells in. Information that customers cannot read does not do its job.

Do not copy the public sector model blindly

Many templates online are built on the model statement for public sector websites under the Web Accessibility Directive 2016/2102, set out in Implementing Decision 2018/1523. That model is mandatory for public bodies, not for shops under the EAA. Its structure (compliance status, non-accessible content, how to give feedback, how to complain) is a reasonable pattern, but on its own it misses what Annex V asks for: a description of your service, how it works, and how it meets the requirements.

An outline you can work from

This outline covers Annex V and the German additions. It is a starting point for your own text, not a legal template, and not legal advice.

1. The service. What you sell, to whom, and through which channels (website, app, phone orders).
2. How it works. Browsing, searching, choosing variants, checkout, payment options, delivery and returns, account features, customer service channels.
3. The standard you work to. For example: "We work to WCAG 2.2 level AA, which covers the web requirements of EN 301 549."
4. How the service meets it. What was tested, when, and how (automated scan plus manual keyboard and screen reader testing), and the main accessibility features customers can rely on.
5. Known limitations. Anything that does not yet meet the standard, the workaround, and when you expect to fix it. Include gaps in third-party parts such as a hosted checkout or payment widget.
6. Exceptions claimed. If you rely on disproportionate burden or fundamental alteration, say so for which part, and keep the documented assessment.
7. Feedback and help. An email address and phone number for reporting barriers and getting help with an order, with your response time.
8. Enforcement. The market surveillance authority for your country and how to contact it (mandatory in Germany).
9. Dates. When the statement was prepared and last reviewed, and when the service was last tested.

Link it from every page (usually the footer) and from your terms and conditions, and make the page itself accessible.

Common mistakes

• Claiming full compliance you cannot prove. A statement that says "fully compliant" while a scan shows failures invites the complaint it was meant to prevent.
• Pointing to an overlay as the accessibility measure. Regulators judge the service, not the widget. See overlays vs code fixes.
• A statement with no testing behind it. Annex V asks how the service meets the requirements. That needs evidence: dated scans, manual test notes, and the fixes made. Our free scan is a first data point; a Fix Sprint produces before and after evidence you can cite.
• Never updating it. Re-test and re-date it after redesigns, platform updates and new apps.

The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025.