EAA Accessibility Statement: Requirements, Template, and Generator

Last updated: October 25, 2026

The European Accessibility Act requires covered service providers to publish an accessibility statement explaining how their service meets the law's accessibility requirements — a legal information obligation under Annex V, not a voluntary courtesy page. This guide covers what the statement must say, a full annotated template, and where to get one drafted from real audit findings instead of a guess.

Key numbers: Annex V of Directive (EU) 2019/882 requires covered providers to publish, in an accessible format, an explanation of how their service meets the applicable accessibility requirements (EUR-Lex). WCAG 2.2 defines 55 success criteria at Levels A and AA — the set a statement's conformance line should name (W3C). Maximum EAA penalties reach €500,000 in some member states, and on June 4, 2026 a French court ordered Carrefour France to make its site and app fully accessible within six months — the first EAA-linked court order of its kind. As of 2026, TestParty has remediated 35 million-plus accessibility issues across 100+ brands, and automated scanning finds roughly 60–70% of issues in TestParty's detection data — the gap a statement's methodology has to admit honestly.

This article is general information about EAA obligations, not legal advice. Whether your business is covered, and exactly what your statement must say, is a question for qualified counsel.

Does the EAA require an accessibility statement?

Yes. Annex V of Directive (EU) 2019/882 requires covered service providers to explain, in their terms and conditions or an equivalent accessible document, how their service meets the law's accessibility requirements — an information obligation, not an optional courtesy page.

Annex V doesn't use the exact phrase "accessibility statement," but the duty it describes — accessibility information available, in an accessible format, within the general terms and conditions "or equivalent" — is what every covered provider ends up publishing under that name. It's distinct from the older Web Accessibility Directive's public-sector statement, which covers government sites rather than private providers; the two differ in origin but converge on nearly the same document, referencing the same standard, EN 301 549. Member states transpose the requirement individually, so exact placement — a standalone page versus a T&Cs clause — varies by country. When in doubt, publish a standalone, permanently linked page: it satisfies every transposition and is easiest to find. See our EAA compliance guide for how the statement fits among the law's other obligations.

What must the statement contain?

A compliant statement names the service it covers, states the standard it targets, explains how the service meets that standard, discloses known limitations honestly, and gives a working feedback channel — available in writing, in an accessible format, for as long as the service operates.

Annex V spells out three required elements: a general description of the service in accessible formats, the explanations necessary to understand how it functions, and a description of how the service meets the applicable requirements in Annex I. For ecommerce, that last piece means naming EN 301 549, the EU's harmonized standard, whose current web clause maps to WCAG 2.2 AA. The statement must be available to anyone visiting the service, and it must be accessible itself — a PDF that fails the standard it claims to meet is a documented contradiction. And it isn't a one-time filing: Annex V expects it to stay available for as long as the service operates, making every remediation cycle a reason to revisit it. Our EAA requirements checklist covers where the statement sits among the law's other 18 obligations.

What does a compliant statement look like?

A compliant statement names the exact service, states EN 301 549/WCAG 2.2 AA as the target, gives an honest conformance verdict, lists known gaps with dates, states how and when it was prepared, and offers a real feedback channel with an escalation route.

The annotated template below is built for Alderwood Home, a fictional composite home-goods retailer shipping to five EU member states. Every excerpt reads the way a real statement should — specific and dated, not like marketing copy.

1. Scope and services covered. Name the exact storefront, app, and market-specific properties covered; "our website" leaves a regulator guessing what was tested.

2. Conformance standard. State the standard and version targeted, cross-referenced to its WCAG level.

3. Conformance status, in honest language. Use "fully conforms," "partially conforms," or "does not conform" — never "fully accessible." Absolute claims are rarely true and are the easiest line in a statement to disprove.

4. Known limitations and a remediation timeline. List specific, dated gaps rather than a vague acknowledgment — a statement that admits nothing invites the scrutiny it was written to avoid.

5. Preparation date and method. State when it was prepared or reviewed and how conformance was assessed — automated scanning alone can't support the claim.

6. Feedback mechanism and contact. Give a named channel and a response-time commitment — an unowned email address reads as decorative.

7. Enforcement and complaint route. Note that a visitor unsatisfied with the response can escalate to a national market-surveillance authority.

TestParty offers a free accessibility statement generator that builds this document from your own audit findings, not a template guess. Until then, TestParty's free Shopify accessibility scanner is the fastest way to see what your statement needs to disclose.

How is this different from a US accessibility statement or a VPAT?

A US accessibility statement is voluntary, a VPAT/ACR is a procurement document answering one buyer's question, and an EAA statement is a legal obligation attached to the service itself — three documents, three audiences, three consequences for skipping one.

Our VPAT vs. ACR vs. accessibility statement comparison works through the procurement-side confusion further. That page answers "which document is a buyer asking for"; this one answers "what the law makes you publish, whether anyone asks or not." A WCAG compliance report is a related fourth document — the fuller evidence file a statement's language should be drawn from.

What are the mistakes that get statements rejected?

The mistakes that draw scrutiny: copy-pasted language with no testing behind it, claims of full conformance that don't survive a five-minute check, no working feedback channel, a statement that isn't itself accessible, and a publish date that never moves.

Copy-pasted boilerplate is easiest to spot: a statement that reads like every other vendor's, names no testing method, and mentions no known gap is one no one actually tested against. Claiming full conformance is the riskiest sentence in the document — "fully accessible" describes something almost no real website is, and it hands anyone who tests the site a documented contradiction. A feedback channel that goes unanswered defeats the process obligation the EAA builds around statements; several member states have flagged non-responsive channels during reporting audits. A statement that isn't itself accessible — a scanned PDF, a page that traps keyboard focus — undermines its own claim. And no update history is stale evidence: on June 4, 2026, a French court ordered Carrefour France to fix its site and app within six months, the kind of outcome that follows once the underlying claims, not just the page's existence, get tested.

How do you keep it current?

Re-issue the statement after every remediation cycle and audit, keep dated prior versions on file as evidence of progress, and set a fixed review cadence rather than waiting for a regulator's request to prompt an update.

Treat the statement as a living document tied to real audit cycles, not a one-time publish. In TestParty's work with EU-facing Shopify and Shopify Plus brands, the statement is regenerated on the same cadence as the underlying evidence — daily automated scans plus monthly expert manual audits feed a dated record, and an initial remediation cycle typically closes the highest-severity limitations within 14 days, exactly the progress the limitations table should reflect. Keep every prior version rather than overwriting it; dated statements showing gaps closing over time are stronger evidence in a regulator's information request than one undated page claiming everything is fine. A practical minimum cadence is quarterly, or immediately after any release touching the storefront or checkout — a statement written for a version of the site that no longer exists is worse than publishing nothing.

Frequently Asked Questions

Does a small Shopify store selling into the EU need an accessibility statement? Yes, unless it clears the EAA's microenterprise exemption — fewer than 10 employees AND turnover or balance sheet total under €2 million, both conditions, company-wide. Most direct-to-consumer brands with meaningful global sales fail the turnover test even at a small headcount.

Can we reuse our US accessibility statement for our EU storefront? Not directly. A US statement is voluntary and rarely names EN 301 549 or a preparation method the way Annex V requires. If you run separate market storefronts, each needs a version localized to that market's language, describing that storefront's actual state.

Where should the statement live on the site? Anywhere permanent and linked from a page shoppers are likely to land on — commonly the footer, alongside privacy and terms links. Annex V accepts the statement inside the general terms and conditions "or equivalent," but a standalone, clearly labeled page is easier to find.

Who inside the company should sign off before it publishes? Two people: whoever ran or supervised the testing, who can defend every specific claim, and a compliance or legal owner accountable for whether the wording itself is defensible. A statement no one will attach their name to shouldn't publish yet.

Does publishing a statement protect us if we're not actually conformant? No. A statement documents a claim; it doesn't create the underlying accessibility. An honest statement naming real gaps and dated fix targets beats either silence or an inflated claim, but it's evidence of the remediation work, not a substitute for it.

Humans + AI = this article. TestParty uses a cyborg approach to content — combining human accessibility expertise with AI capabilities to produce accurate, comprehensive guides. This content is for educational purposes and reflects our analysis of publicly available information as of the publication date. TestParty competes in the digital accessibility market, and we encourage readers to evaluate all solutions independently based on their specific needs.