Accessibility statement: what goes in it and which mistakes to avoid
· 5 min read
A good accessibility statement describes your shop, explains how it is used and sets out how it meets the accessibility requirements, including the points that are not done yet. The most common mistakes are copied templates, exaggerated claims, missing contact options and statements that are not accessible themselves. This article shows a sample structure and ten mistakes from practice.
Note: this article is not legal advice. Agree your statement with your legal adviser.
What this is about
Section 14 of Germany’s Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) requires service providers to give information on how their service meets the accessibility requirements. The information goes into the general terms and conditions or is made available in another clearly perceptible way, and it must be accessible itself. Annex 3 names, in essence, three contents: a general description of the service, explanations of how it is carried out and a description of how the requirements are met. At EU level, this corresponds to Article 13 and Annex V of the European Accessibility Act.
The obligation applies to businesses that offer covered services to consumers and are not microenterprises. Whether that applies to you is answered by the three questions in the guide Who is affected?.
Many shops meet the obligation with a dedicated page linked in the footer of every page. That is clear and easy to find.
A sample structure
The following structure is a suggestion, not an official template. Sections 1 to 3 follow Annex 3; the others are common additions.
1. About this shop “We sell sports and outdoor clothing to private customers in Germany and Austria. You can browse, order and pay for our range in the browser on a computer, tablet and smartphone. Our customer service is available by email and contact form.”
2. How ordering works Search and filters, product page with size selection, cart, checkout with guest or customer account, payment methods, shipping, returns – one or two sentences each.
3. How we meet the requirements “We follow the EN 301 549 standard and WCAG 2.2 at level AA. Among other things, we have implemented: operation of all functions by keyboard, visible focus, text alternatives for product images, sufficient contrast, labelled form fields and error messages in plain language. We check the shop automatically every week and regularly test the checkout with a keyboard and a screen reader.”
4. Known limitations “The size charts of some brands are currently available only as images. We will add text versions by the end of the quarter. Until then, our customer service will be happy to help.”
5. Feedback and contact An email address and a second contact channel, with a note that people can report barriers and request information in another format.
6. Competent authority In Germany, the joint market surveillance authority of the federal states for the accessibility of products and services (MLBF) in Magdeburg.
7. Date Date of creation and of the last review.
A detailed outline with explanations is in the accessibility statement guide.
The ten most common mistakes
1. A copied template with no connection to the shop
A statement that fits every shop word for word describes none of them. Annex 3 requires a description of your service.
2. Claims without testing
“Our shop meets all requirements” is a strong statement. If a simple check shows the opposite, the statement becomes a problem. Write what has been implemented and back it up internally with test results.
3. No known limitations
Hardly any shop is free of barriers. An honest section on limitations with a timeline is more credible than perfection on paper.
4. An overlay as the solution
“Our accessibility widget makes the shop accessible to everyone” – an overlay does not change the code. A sentence like that tends to draw attention to unsolved problems. Background in our article Overlays are not a solution.
5. No contact for feedback
Without a feedback channel, people cannot report barriers – and you never hear about them.
6. A statement that is not accessible itself
A scanned PDF, an image of text or a page without a heading structure defeats the purpose. The statement should be a normal, well-structured HTML page.
7. Hard to find
Hidden in subpages of the legal notice or only as a link in the privacy policy? Better: a dedicated link in the footer of every page and a reference in the terms and conditions.
8. Out of date
After a relaunch or a platform change, the description, functions and limitations are often no longer accurate. Plan a review with every major change.
9. Confusion with the statement for public bodies
Public bodies use their own template under Directive (EU) 2016/2102, with fixed wording on compliance status. For businesses, Section 14 BFSG and Annex 3 apply; a public-sector template fits only partly.
10. Only one language for several markets
If you also sell in Poland, Czechia or Romania, provide the information in the language of each market. The country overviews are at EAA in Poland and EAA in Czechia.
Why a scanner cannot write the statement on its own
A scanner sees the code of your pages, but not your service: it does not know which channels you offer, how your customer service works or which features you deliberately built for accessibility. It can, however, reliably supply what belongs in the “Known limitations” section.
That is why we work with a questionnaire: you answer questions about your offer, channels and features, and our automated check adds the technical limitations. The result is a draft in the language of the target country, marked as a template for your legal adviser. The check is an automated check, not a full audit, and not legal advice.
Final checklist
- [ ] Does the statement describe your shop specifically?
- [ ] Does it explain how ordering and customer service work?
- [ ] Does it describe how the requirements are met – and which standard you follow?
- [ ] Is there an honest section on limitations with a plan?
- [ ] Are the contact and the competent authority named?
- [ ] Is the page linked in the footer and accessible itself?
- [ ] Is there a current date at the bottom?
Our BFSG guide summarises the legal framework.