Skip to content
Pandus

The EAA accessibility statement: content, structure and mistakes

Updated October 12, 2026 · 3 min read

Under the European Accessibility Act, a covered service provider must publish information on how its service meets the accessibility requirements (Article 13 and Annex V of Directive 2019/882). It belongs in the general terms and conditions or an equivalent document, in an accessible format. In Germany the same duty is in §14 and Annex 3 of the BFSG, and shops often publish it as a separate "Barrierefreiheitserklärung" page.

Who needs one

Only providers of covered consumer services that are not micro-enterprises — for example, an online shop with 10 or more employees selling to consumers in the EU. If the EAA does not apply to you, you have no legal duty, although a short page about accessibility can still help customers. Check with the three-question filter.

What Annex V asks for

The information must include, as a minimum:

  1. A general description of the service in accessible formats.
  2. Descriptions and explanations needed to understand how the service works.
  3. A description of how the service meets the relevant accessibility requirements.

National laws may add details, so check the law of the countries where you sell: Germany, Poland, Czechia, Romania.

A practical structure

Section What to write
About the service What you sell, through which channels (website, app, phone, email), in which countries
How the service works How customers find products, order, pay, receive confirmations and get support
Accessibility features What you have done: keyboard access, contrast, labelled forms, text alternatives, captions, alternative contact channels
Standard used The standard you measure against, e.g. EN 301 549 / WCAG 2.2 AA
Known limitations Areas that are not yet accessible and when you plan to fix them
Feedback and contact How customers can report a barrier and get help
Supervisory authority The authority responsible in your country, if your lawyer recommends naming it
Date When the information was last reviewed

Where to publish it

Annex V says the information goes into the general terms and conditions or an equivalent document. Many shops add a dedicated page and link it from the footer and from the terms. Whatever you choose, the information itself must be accessible — an image of text or an untagged PDF is not.

Common mistakes

  • Copying a public sector template. The statement under Directive 2016/2102 is for public bodies and has a different structure.
  • Claiming full conformance after an automated scan. Automated tools find only part of the issues.
  • Listing only scan errors. Annex V asks for a description of the service and how it meets the requirements, not a bug list.
  • No date and no owner. The statement goes out of date with every redesign.
  • No contact route. Customers need a way to report barriers and get the service another way.
  • Wrong language. Publish it in the languages your shop uses.

How our draft generator works

A scan cannot write this text, because it must describe your service. We therefore ask 10–15 questions about your service: channels, support options, alternative ways to order, existing accessibility features and who is responsible. Your scan results feed only the "known limitations" section. You get a draft in the language of your country, marked as a draft for your lawyer. It is not legal advice, and our scan is an automated check, not a full audit.

Related reading: EAA guide, WCAG 2.2 checklist. Start with a free check.

Sources

  • Directive (EU) 2019/882, Article 13 and Annex V, EUR-Lex: https://eur-lex.europa.eu/eli/dir/2019/882/oj
  • BFSG §14, gesetze-im-internet.de: https://www.gesetze-im-internet.de/bfsg/__14.html