Accessibility statement: who needs one, what goes in

Two rules, two documents

Public bodies: under Directive (EU) 2016/2102 they must provide and regularly update a detailed, comprehensive and clear accessibility statement for their websites and apps. It must be in an accessible format and follow the model in Implementing Decision (EU) 2018/1523 (Art. 7(1)).

Businesses: under the European Accessibility Act, Directive (EU) 2019/882, service providers prepare information on how their service meets the accessibility requirements (Art. 13(2) and Annex V). It goes in the general terms and conditions or an equivalent document, in written and oral format, accessible to persons with disabilities, for as long as the service runs. Germany asks for this in § 14 BFSG with Annex 3, Poland in art. 32(2)(1) of the act of 26 April 2024. Who is covered at all is explained in our guide on accessibility law for small online shops.

Public bodies: what the EU model asks for

• Compliance status: fully, partially or not compliant with the named standard or law. The first option only if all requirements are met without exceptions.
• Non-accessible content by reason: non-compliance, disproportionate burden, or outside the scope of the law. Name accessible alternatives where appropriate and describe problems in non-technical terms.
• Preparation: the date, the method (for example a self-assessment or an assessment by a third party) and the date of the last review.
• Feedback: a link to a way of reporting problems and asking for content that is not accessible, plus a contact.
• Enforcement: a link to the procedure for unsatisfactory answers and the contact of the enforcement body.
• Place: a link on the home page or on every page, for example in the footer.

Businesses: what the laws list

• EU, Annex V: a general description of the service in accessible formats, the explanations needed to understand how it works, and a description of how it meets the accessibility requirements.
• Germany, Annex 3 BFSG: the same three elements, plus the responsible market surveillance authority.
• Poland, art. 32(2)(1) and art. 33: the same three points, plus information on the accessibility of premises used for the service or an accessibility certificate, where that applies. For e-commerce, the market surveillance authority is the minister responsible for digitalisation (art. 38(3)).
• Poland also lets consumers complain to the business about missing accessibility. The business must answer within 30 days (art. 35 to 37).

The business texts do not list a compliance status, known barriers, a feedback contact or a date as separate items. They also do not say explicitly whether you must name what does not meet the requirements yet. Many providers add these parts anyway and use the public sector model as a guide. Treat them as voluntary, and ask the authority if you need certainty.

A practical outline

Whichever rule applies, a statement that people can use often has these parts:

1. 1Scope: which website or app, and who provides it.
2. 2Status: how it meets the requirements, and against which standard or law you checked it.
3. 3Known barriers: each in plain words, with the reason and your plan.
4. 4Alternatives: for example ordering by phone or email.
5. 5Contact for problems, and the authority where one must be named.
6. 6Date and method of the check, and the date of the last review.

Keeping it current

Public bodies must update the statement regularly (Art. 7(1) of Directive (EU) 2016/2102). The implementing decision encourages a review at least once a year and recommends a new evaluation after a substantial revision of the website.

Businesses must take changes to the service, the requirements and the standards into account (Art. 13(3) of Directive (EU) 2019/882, § 14(3) BFSG, art. 32(2)(4) of the Polish act). In practice: update the text after a relaunch, a new checkout or payment provider, and whenever you fix or find a barrier. Then change the date.

Work with Do4U

The Accessibility statement tool builds a draft without AI, from a fixed template and your answers, for Germany, Poland or another EU country, in English, German or Polish. It has sections for scope and provider, the service, how it meets the requirements, known barriers, alternatives and contact, and the market surveillance authority, each with its reference. You can take over the findings of your own accessibility check or website check.

The template is made for businesses that offer services to consumers. Public bodies should use the EU model. Fill in the placeholders in square brackets before you publish. A check finds technical issues and the draft gives you a structure, but whether the statement is complete and correct needs a manual review.