Search for "EAA accessibility statement template" and you will find the same
twelve-section document over and over. Conformance status, non-accessible
content, preparation date, feedback mechanism, enforcement procedure. It looks
official because it is official.
It is also written for a different directive, aimed at organisations you are
probably not one of.
That template comes from Implementing Decision (EU) 2018/1523, which sets out
the model accessibility statement for the Web Accessibility Directive
(2016/2102). The Web Accessibility Directive applies to public sector bodies
ministries, municipalities, state hospitals, public universities.
The European Accessibility Act is a different instrument with a different scope,
and it does not prescribe a template at all.
Copying the public-sector model is not a disaster. Much of it is sensible, and
national transpositions differ yours may well ask for something close to it.
Check what your own member state actually enacted, because that is the text that
binds you, not the directive in the abstract. But if you copy the model believing
it is the EAA requirement, you will
confidently produce a document that satisfies a rule you are not subject to while
missing two obligations you are.
One caveat with a date on it, because I would rather flag this than have the
article age into a lie. The revision of EN 301 549 is being carried out under
Commission Standardisation Request M/587, which covers both the EAA and the
Web Accessibility Directive. Work under that mandate has included establishing a
model accessibility statement. So "the EAA prescribes no template" is true as I
write this and may not stay true. If a model arrives through the harmonised
standard, use it a template that carries a presumption of conformity is worth
more than any structure I can suggest.
Before any of this: does it apply to you?
Microenterprises providing services fewer than ten people, and annual turnover
or balance-sheet total not over €2 million are exempt from the EAA's service
obligations. That exemption does not extend to product manufacturers, and it does
not exempt you from other law.
If you are under those thresholds, the rest of this article is optional reading
rather than a compliance task. Publishing an honest statement is still a good
idea. It is just not the same as being obliged to.
What the EAA actually asks for
Article 13(2) puts the duty on service providers plainly: prepare the information
required by Annex V, and explain how the service meets the applicable
accessibility requirements.
Annex V then lists what that information contains:
- A general description of the service in accessible formats.
- Descriptions and explanations necessary for understanding how the service operates.
- A description of how the relevant accessibility requirements in Annex I are met.
Three items. No conformance percentage, no prescribed headings, no template.
That is more demanding than it first appears, because point 3 is not "we ran a
scanner". Annex I is the accessibility requirements themselves. You are being
asked to walk through what applies to you and describe how you meet it.
The two obligations the public-sector template will not remind you about
It goes in your terms and conditions
The directive says the information assessing how your service meets the
accessibility requirements belongs in the general terms and conditions, or an
equivalent document.
The pattern you see almost everywhere is a page at /accessibility linked from
the footer, and nothing else. That page is useful and you should keep
it but on its own it is not where the directive says the information lives.
If your terms and conditions are a separate document a customer accepts at
checkout, that document, or something equivalent to it, is where this has to
appear.
It has to exist in oral format too
Article 13(2) requires the information be available in written and oral
format, and in a manner accessible to persons with disabilities.
Oral. This is the requirement I have seen discussed least and skipped most.
It does not mean recording a podcast. In practice it means somebody who telephones
your support line and asks how accessible your service is must be able to get the
answer that way which implies your support staff know it exists and can read it
out or explain it. A statement your own support team has never seen fails this
quietly and completely.
What makes a statement survive being read by a hostile expert
The three ways statements fail have nothing to do with formatting.
Claiming conformance you cannot support
"This website is fully compliant with WCAG 2.1 AA" is the single most common
sentence in generated statements, and it is almost never true.
Automated testing detects roughly a third of accessibility barriers. If nobody has
tested with a screen reader, nobody has tabbed the full checkout, and nobody with
a disability has used the thing, then the honest status is partially conformant,
and saying so costs you far less than the alternative.
The alternative is documented. In January 2025 the US Federal Trade Commission
brought a case against accessiBe over claims that its widget could make any site
WCAG compliant, and
approved a final order in April
requiring the company to pay $1,000,000. The complaint also covered reviews
presented as independent that were not. Different jurisdiction, same principle: an
accessibility claim is a claim, and unsupported claims are actionable.
Your statement carries your organisation's name, not your vendor's.
Being silent about what was never checked
A statement that lists three known issues implies the rest was examined and passed.
If your evidence is one automated run, several clauses were never evaluated at all consistent navigation, keyboard operability across a whole journey, whether alt
text actually communicates anything. Silence about them reads as a pass, and that
inference is the thing you did not intend to make and will be held to anyway.
Name them. "These were not assessed" is a defensible sentence. "We are fully
compliant" when they were not assessed is not.
Offering a feedback route that does not work
Every model statement includes a contact for reporting barriers. Most of those
addresses go to a mailbox nobody reads.
The feedback mechanism is not decoration. It is the thing a regulator will test
first, because it takes them thirty seconds and it tells them whether the rest of
the document is real. Send a message to your own accessibility contact and see
what happens.
A structure that works
Not a template to paste the EAA prescribes none, and your service is not mine.
But this order holds up:
What this service is, in plain language. Annex V point 1, and the place to be
concrete rather than corporate.
Current status, stated exactly as strongly as your evidence supports. If the
evidence is automated testing only, say that in the same sentence as the status.
How the requirements are met, walking the applicable parts of Annex I. This is
the substance, and it is the part a template cannot write for you.
What is not accessible yet, with what you intend to do and roughly when. A
known issue with a date attached reads as competence. The same issue undisclosed
reads as concealment.
What was not tested, named clause by clause rather than left to inference.
How to tell us, with a route somebody actually monitors and a response time you
will actually hit.
When this was prepared and how, including what tooling and what manual
testing. A statement with no date and no method is an assertion.
Where a tool helps, and where it does not
Curbcut drafts the evidence-based parts. It maps findings
onto EN 301 549 clauses, ranks them by regulatory exposure rather than by how
loudly a rule engine complains, and generates a statement draft.
The generator deliberately will not produce a full-conformance claim from scan
data, because scan data cannot support one. Everything requiring a human decision
stays a visible [bracket] until a human fills it in. Brackets in a draft are
annoying. Brackets are also the only honest output when the input is one automated
run.
npx curbcut https://example.com --crawl --statement
Or check a page in your browser with nothing installed,
which is the faster way to see what your evidence actually looks like before you
write anything.
The honest part
I am not a lawyer and this is not legal advice. Whether the EAA applies to you,
what your national transposition adds, and whether a particular statement
discharges your obligation are legal questions about your business.
What I can tell you is that automated testing reaches about a third of the
problem, that a statement is a public claim about the other two thirds, and that
the gap between those two facts is where organisations get into trouble.
Write the statement you can defend, not the one you would prefer to be true.
