EU Accessibility Act

How to write an EAA accessibility statement (without overclaiming)

Conformly·

The instinct, when you sit down to write an accessibility statement, is to reassure: "This website is fully accessible and compliant with WCAG 2.1 AA." That sentence feels responsible. It's actually the single most dangerous line you can publish.

Your accessibility statement under the European Accessibility Act is a legal document, not a marketing badge — and a claim of total compliance is a representation you almost certainly can't defend. Here's what the statement is for, what the law requires it to contain, and how to write one that protects you instead of exposing you.

Where the obligation comes from

Two pieces of the EAA matter here. Article 13(2) requires service providers to prepare information, in line with Annex V, explaining how their service meets the accessibility requirements. That information has to be made public in written and oral format, in a way that is itself accessible to people with disabilities, and kept available for as long as the service is in operation. Article 13(3) adds that you must have processes in place to stay in conformity over time.

A common mistake is to reach for a public-sector accessibility-statement template. That belongs to a different regime (the Web Accessibility Directive for public bodies). The EAA's service-provider obligation is its own thing — don't just clone a government template and assume you're covered.

What Annex V actually asks you to include

Annex V says the assessment of how your service meets the requirements should sit in your general terms and conditions, or an equivalent document, and should cover, as relevant:

  • a general description of the service in accessible formats;
  • the descriptions and explanations needed to understand how the service operates;
  • a description of how the service meets the applicable accessibility requirements set out in Annex I.

That's the legal core. In practice, a statement that only does the bare minimum reads as evasive — so the useful version goes a little further.

A practical checklist

A statement that is both compliant and credible tends to include:

  • A plain-language description of what the service is and does.
  • How it meets the requirements, referencing EN 301 549 / WCAG 2.1 AA as the standard you work to — framed as the benchmark you build against, not a guarantee.
  • Known limitations — the parts that aren't fully accessible yet. Naming these honestly is protective, not embarrassing.
  • How to use the accessibility features you do provide.
  • A feedback and contact route so someone hitting a barrier can report it, and what they can expect in response.
  • How you monitor accessibility over time (audits, re-checks, fixes).
  • A date, and a commitment to keep the statement current.

Why "fully compliant" is the trap

No honest statement — and no honest tool — can promise total accessibility. Accessibility is continuous, context-dependent, and partly a matter of how real assistive technology meets real content. The moment you publish "fully compliant," you've made a factual claim that a single discovered barrier can disprove. At that point your own statement becomes evidence that you overstated, which is worse than having claimed nothing.

The defensible posture is the honest one: say what you've done, name what you're still working on, and give people a way to reach you. This isn't only the ethical position — it's the legally safer one. A statement that describes real, ongoing work is far stronger than one that claims a finish line no service ever truly crosses.

Bring it back to action

A good statement describes real work, so it starts with knowing where you actually stand. Find out what an automated scan can see on your most important page — under a minute, no cost: run a free audit.

If Germany is your market, the BFSG fines breakdown covers how documentation checks work there. For the EU-wide enforcement picture, see fines by country, and for what actually happens if an authority finds a gap, the cure window.

This article is general information, not legal advice. It summarises the European Accessibility Act (Directive (EU) 2019/882) and is subject to national transposition and change. Confirm your obligations with qualified counsel for your specific situation.

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