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The accessibility statement: what belongs in it – and what is missing almost everywhere

Two duties carry almost the same name, and they ask for the opposite of each other: public sector bodies must disclose what is not accessible about their website. Private service providers must describe how their service meets the requirements. This article shows which of the two applies to you, what belongs in it – and gives you a template to copy for both.

Updated on 1 September 2026 · Libration editorial team · 10 min read
The short version Public sector bodies owe an accessibility statement under Article 7 of Directive (EU) 2016/2102, as transposed into national law – at its core a report of defects with a contact route. Private service providers owe information on accessibility under the European Accessibility Act, Directive (EU) 2019/882 – at its core a description of conformity. Publishing the wrong document does not discharge either duty, even when a page with the right heading is online.

The one requirement you can finish in an afternoon

Every three years each Member State monitors the accessibility of public sector websites and reports the result to the European Commission (Article 8 of Directive (EU) 2016/2102). Germany's report for the 2022–2024 monitoring period examined 7,239 websites and 269 mobile applications. Three figures from it:

FindingShare of the websites examined
Had an accessibility statement at all47.75 % (2020/21: 36.13 %)
Met the Directive's requirements for that statementaround 13 %
Reached the required conformity level AAfewer than 5 %

These are German numbers, but the reporting duty is the same across the Union, and so is the pattern behind them. The third figure represents months of work – not a single website and not a single app examined was fully accessible. The first one does not. An accessibility statement requires no line of code. It requires you to know where your site stands, and to write it down. That is exactly why it is missing: writing one honestly means looking first, and many would rather not have the answer in black and white.

That is a misreading. The statement is not an admission of guilt; it is the mechanism the law provides for running an unfinished website lawfully. An honest statement with a list of defects and a timeline is legally sound. A missing statement is a breach – no matter how good the site is.

Which duty applies to you?

Who you areWhat you oweLegal basis
State, regional or local authorityAccessibility statementArt. 7 Directive (EU) 2016/2102, as transposed
Municipality, school, university, public agencyAccessibility statementnational transposition (in Germany: state equality acts and state BITV)
Association or provider financed for the most part from public fundsAccessibility statement"body governed by public law", Art. 3(1) of the Directive referring to Art. 2(1)(4) of Directive 2014/24/EU
Company or association with a shop, booking or customer accountInformation on accessibilityArt. 13(2) and Annex V of Directive (EU) 2019/882 (EAA)
Microenterprise providing services onlyneitherArt. 4(5) EAA

The row most people trip over is the third. "Public sector body" is not a synonym for "government". The Directive borrows the procurement definition of a body governed by public law: any legal person established for the specific purpose of meeting needs in the general interest, not having an industrial or commercial character – provided it is financed for the most part by public authorities, is subject to their management supervision, or has a board more than half of whose members they appoint. "For the most part" means more than half of the funding.

The case almost everyone misses A welfare organisation, an advice centre or an education provider drawing more than half of its funding from public sources is, as a rule, a public sector body – and owes an accessibility statement, not just the information required by the EAA. If the same organisation also runs an online booking for consumers, both duties apply side by side. Which national rules govern usually depends on the level that funds it, but the national versions follow the same European pattern. Who is covered by the EAA and which deadlines apply is set out in detail in The European Accessibility Act: who must comply, and by when?; our EAA check answers the question in three steps.

Part 1: The accessibility statement

Its content is harmonised across Europe. Commission Implementing Decision (EU) 2018/1523 sets out a model statement whose components are binding – Member States may add, but may not leave anything out. These nine items have to be in it:

ItemWhat matters
ScopeWhich domain or app does the statement cover? One statement per site, not one for all of them.
Compliance statusExactly one of three wordings: fully compliant, partially compliant, or not compliant. "Largely" and "mostly" are none of the three.
Non-accessible contentSplit into three reasons: non-compliance with the requirements, disproportionate burden, or content outside the scope of the legislation.
AlternativesWhat do you offer while the content is not accessible – a phone line, an appointment, the document on request?
Method of assessmentSelf-assessment or third-party evaluation? Article 3 of the Implementing Decision requires the method to be stated; a link to the report is optional.
Date of preparationWhen was the statement drawn up?
Date of last reviewThe model statement asks for the accuracy of the claims to be reviewed regularly and at least once a year – so the date should never be more than twelve months old.
Feedback mechanismAn accessible contact route for reporting barriers and requesting content that is not accessible.
Enforcement procedureA reference to the national enforcement or conciliation body, with contact details, for cases where the reply is unsatisfactory.

Two formalities from Article 2 of the Implementing Decision are easy to overlook: the statement must be provided in an accessible format – a scanned PDF does not qualify – and, where appropriate, in a machine-readable format. Several Member States have made both binding and added their own rules on placement and response times. Germany, for example, requires the statement to be reachable from the home page and from every subpage through a single link, in practice from the footer, and obliges public sector bodies to answer reports from the feedback mechanism within one month.

Template to copy – public sector bodies

Accessibility statement [Name of the body] is committed to making [domain] accessible in accordance with [national legislation transposing Directive (EU) 2016/2102].

Compliance status This website is partially compliant with [legal basis] due to the non-compliances listed below.

Non-accessible content 1. [e.g. PDF documents published before 23 September 2018 – these fall outside the scope of the legislation.]
2. [e.g. videos without captions – non-compliance with success criterion 1.2.2. Captions will be added by DD/MM/YYYY.]
3. [e.g. the map in the events calendar – disproportionate burden. Alternative: the postal address is given in the text above it.]

Preparation of this statement This statement was prepared on [DD/MM/YYYY] and last reviewed on [DD/MM/YYYY]. It is based on [a self-assessment / an evaluation carried out by …].

Reporting barriers Have you found a barrier, or do you need content in an accessible form? Write to [email] or call [phone]. We reply within one month.

Enforcement procedure If you are not satisfied with our reply, you can contact [the competent national enforcement or conciliation body, with address, email and website].

Part 2: Information on accessibility under the EAA

Since 28 June 2025, service providers covered by the European Accessibility Act may only offer a service if it meets the accessibility requirements and they have prepared the information required by Annex V. That information goes into the general terms and conditions, or an equivalent document, and it has to assess how the service meets the requirements of Annex I. Annex V names three elements:

  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 accessibility requirements of Annex I are met by the service.

National transpositions may add to that list, and several have. Germany's Barrierefreiheitsstärkungsgesetz (BFSG) requires a fourth element in Annex 3 – the competent market surveillance authority, which nationwide is the MLBF in Magdeburg – and specifies that the information must be accessible "in a clearly perceptible and easily findable way". In practice that means what it means everywhere: a separate link in the footer, next to the legal notice. Which body is competent, and what the national additions are, differs by country; our overview of how EU countries implemented the EAA collects them.

The decisive difference The EAA has no list of defects. It assumes the service meets the requirements; the information only describes how. Copying the structure of the public sector statement and writing "partially compliant" with a list of open issues publishes a written admission that the service is being offered in breach of the Act. The exemptions for disproportionate burden live elsewhere in the Directive and require a documented assessment – they are not a sentence in the footer.
Template to copy – private service providers

Information on accessibility This information concerns [domain], operated by [company, address], and is provided in accordance with [the national legislation transposing Directive (EU) 2019/882].

The service Through [domain], consumers can [e.g. order and pay for goods / book appointments / manage a customer account].

How the accessibility requirements are met The website is designed in accordance with the applicable accessibility requirements. It can be operated entirely by keyboard, content is available to screen readers, text meets the required contrast ratios, form fields are labelled, error messages name the error in text, and the page remains usable at 200 % zoom. The benchmark applied is [e.g. EN 301 549 in conjunction with WCAG 2.1 level AA]. The last review took place on [DD/MM/YYYY] by [self-assessment / …].

Contact in case of problems If you encounter a barrier, write to [email].

Competent market surveillance authority [Name, address, email of the authority competent in your country – in Germany: Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), Carl-Miller-Straße 6, 39112 Magdeburg]

Six mistakes found in almost every statement

A survey of the statements published by 28 universities in North Rhine-Westphalia in autumn 2022 shows the pattern in miniature: 23 had a statement at all, but only three of them were from the current year – ten dated from 2020, one from 2019. Against a duty to review annually, those are no longer formalities.

  1. It is out of date. A date three years old tells the reader that nobody is looking any more. Put an annual reminder in the calendar and tie it to a test run – it is the cheapest measure in the entire field.
  2. "Partially compliant" without the list. Stating the compliance level without enumerating the defects is the most common substantive gap – and the only one a reader spots immediately.
  3. The feedback mechanism is a dead end. A generic info@ address with nobody responsible satisfies the letter, but no one replies within a month. Name a person or an inbox that someone actually reads.
  4. The enforcement procedure is missing. The reference to the enforcement or conciliation body is mandatory and is forgotten most often, because it feels uncomfortable. It is precisely the part that turns the statement from self-description into a legal document.
  5. It cannot be reached from every page. A statement linked only from the legal notice fails the placement rules in most Member States.
  6. It is the wrong document. A municipality with an EAA text, or an online shop with a list of defects modelled on the public sector statement – both have been turning up since the EAA became applicable, and neither discharges the duty in question.

Frequently asked questions

Do I have to make my website accessible before I publish a statement?

No – for public sector bodies it is the other way round. The statement is made for the unfinished state: it names what is missing, why, and what you offer instead. Under the EAA it is different; there the duty presupposes that the requirements are met.

Is a self-assessment enough, or do I need an external audit?

A self-assessment is legally sufficient, but it has to be identified as one. Article 3 of Implementing Decision (EU) 2018/1523 makes the method of assessment a mandatory item – leaving it out means the statement is incomplete.

How often does the statement have to be updated?

The model statement asks for the claims to be reviewed regularly and at least once a year, and several Member States have made an annual review plus a review after every substantial change binding. The date of the last review belongs visibly in the statement.

Does the EAA or the Web Accessibility Directive apply to our association?

That depends on the funding, not on the legal form. If the association is financed for the most part from public funds, is subject to public management supervision, or has a board more than half of whose members are publicly appointed, it is as a rule a public sector body and owes the accessibility statement. If it also offers consumers a shop, a booking or a customer account, the EAA duty comes on top. Both at once is possible.

What happens if the statement is missing?

For public sector bodies, the national monitoring bodies check whether a statement exists as part of the monitoring under Directive (EU) 2016/2102 and object when it does not; on top of that comes the enforcement procedure that affected users can start. Under the EAA it is sharper: Article 30 requires Member States to lay down effective, proportionate and dissuasive penalties, and several have made the missing information an administrative offence – in Germany, § 37 BFSG provides for fines of up to EUR 100,000.

Before you write "partially compliant", you should know what exactly it refers to. Our free scan shows you, without signing up, which errors are actually on your website – the list it produces is the raw material for the "non-accessible content" section.

Scan your website now →

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