How to write an EAA accessibility statement (with ecommerce template)

If the EAA applies to your business, publishing an accessibility statement isn't optional, it's a separate legal obligation under Article 13 of the Directive, distinct from actually being accessible. You can build the most accessible checkout in Europe and still be non-compliant if you haven't published a statement covering what Annex V requires: how your service meets accessibility requirements, what falls short, and how someone can report a problem or ask for help. Below is exactly what to include, and a template you can adapt.

If you haven't yet worked out whether the EAA applies to you at all, start with our guides on does the EAA apply to my UK business and the microenterprise exemption, this guide assumes you already know you're in scope.

This is a separate requirement from being accessible

This point trips up more businesses than almost anything else in the EAA. Article 13(2) of the Directive requires service providers to prepare information, in accordance with Annex V, explaining how their service meets the applicable accessibility requirements. That's a distinct, standalone obligation. It sits alongside your actual accessibility work, not inside it.

In practice, this means two businesses can be in an identical technical position, say, both genuinely WCAG 2.2 AA conformant, and one is compliant with the EAA while the other isn't, purely because only one of them has published a statement. Annex V is explicit that this information should be included in your general terms and conditions or an equivalent document, and cover, as far as relevant, the design and operation of your service.

What the statement needs to cover

Based on Annex V and the consistent pattern across how EU member states have transposed it into national law, a proper EAA accessibility statement should include:

1. A general description of your service, in accessible formats, plain, clear language a non-technical visitor can understand.
2. Your conformance status, whether you're fully conformant, partially conformant, or working toward the applicable accessibility requirements, and against what standard (typically WCAG 2.2 Level AA / EN 301 549).
3. A description of known limitations, specific areas where your service currently falls short, and, where relevant, why.
4. A working feedback mechanism, a real way for someone to report an accessibility barrier or request information in an accessible format. This needs a postal address, an email address, and, where applicable, a phone number, with a genuinely monitored inbox behind it, an autoresponder that nobody reads afterward does not satisfy this.
5. A disproportionate-burden disclosure, where relevant. If you've invoked Article 14 to argue that meeting a specific requirement would be disproportionately burdensome, the statement must say so and explain the reasoning, rather than simply going quiet on that requirement.
6. The date of your last assessment or review. Regulators and courts have consistently treated an undated, clearly stale statement as a weak position, it signals the statement was written once and forgotten, not actively maintained.
7. A link to the relevant enforcement authority for your visitors' location, so someone who isn't satisfied with your response has a clear next step.

A note on the feedback mechanism specifically

This is worth calling out on its own, because it's the part most commonly done badly. A feedback mechanism that exists on paper but doesn't actually work in practice, a broken contact form, an email address nobody checks, a phone number that rings out, is treated as a real, documented gap in its own right, not a minor oversight. If you're going to publish a contact route, make sure it's genuinely staffed and that whoever answers it knows what an accessibility complaint looks like and what to do with it.

How often to review it

Guidance across member states generally points to reviewing your statement at least annually as a baseline, though how often you should realistically revisit it depends on how frequently your site changes. For an ecommerce store adding products, running seasonal redesigns, and updating checkout apps regularly, a quarterly review is a more honest match for how often something could have genuinely changed since you last checked. Whatever cadence you choose, the review date on the statement itself needs to reflect reality, a statement dated two years ago on a site that's changed considerably since is a weak position to be in if anyone ever asks.

ecommerce accessibility statement template

Adapt this to your actual situation. Don't publish anything here as fact until you've genuinely checked it, an inaccurate statement is arguably worse than none at all, since it invites a direct challenge on specific claims rather than a general gap.

Getting the "what we've done" section right

The weakest accessibility statements are vague ("we care about accessibility for all our users") because there's nothing in them a regulator, a customer, or a lawyer can actually check. The strongest statements are specific and honest: what standard you're working to, what testing you've actually done, and what you know is still outstanding. If you've had a manual audit carried out, say so and name the standard it was tested against, that's exactly the kind of concrete, checkable detail that makes a statement credible rather than decorative.

Where to publish it

Most businesses publish this as its own page, commonly linked from the footer, rather than burying it inside general terms and conditions, even though Annex V technically frames it as sitting within your terms or an equivalent document. A dedicated, easy-to-find page is the more practical and more commonly adopted approach, and it's easier for a visitor (or a regulator) to actually locate.

Not sure what your statement should honestly say yet?

For a genuinely accurate picture you can confidently put your name to in a statement, our manual audit tests your actual site by keyboard and screen reader across your real purchase journey, and gives you a dated, specific findings report, exactly the kind of detail that makes a strong accessibility statement possible.

See what's included in our audits, from £350

Frequently asked questions

Do I need an accessibility statement if my site is already fully accessible?

Yes. The statement is a separate legal requirement under Article 13, not a way of flagging problems only. Even a fully conformant service needs a published statement describing that conformance, the standard it's measured against, and how to give feedback.

What happens if I don't publish one?

A missing accessibility statement is one of the easiest non-conformities for an enforcement authority to identify, since it doesn't require testing your site at all, the absence is the finding. You can be in breach of the EAA purely for not publishing a statement, regardless of your site's actual accessibility.

Can I just copy a template from another company's site?

No, the statement needs to reflect your actual, specific situation: your real testing, your real known limitations, and a genuinely monitored contact route. A copied statement that doesn't match reality is a liability, not a shortcut, since it makes claims about your service that may not be true.

Does the microenterprise exemption cover the accessibility statement requirement too?

Yes, in the sense that if you're properly exempt from the EAA's service accessibility requirements as a microenterprise, the statement obligation doesn't apply to you either, since it flows from the same underlying requirement. But if you're not certain you qualify, check our guide on the microenterprise exemption before assuming you're covered.

How often do I actually need to update it?

At minimum, annually, but for an ecommerce site that changes regularly (new products, redesigns, checkout app updates), a quarterly review is a more honest match for how often your actual accessibility position could have changed. The date on the statement should always reflect a genuine, recent review, not just the date it was first published.