The short answer

Under the European Accessibility Act, your statement must describe your service, explain how it works, and explain how it meets the accessibility requirements. It must be available in writing and orally, be accessible itself, and stay available as long as the service runs. There's no official template, and it's not the same as the Dutch government's A to E statement.

The short version

  • The EAA calls it "information" on how your service meets the accessibility requirements. In practice, people call it an accessibility statement.
  • It needs three things: a general description of your service, an explanation of how it works, and how it meets the requirements.
  • It has to be available in writing and orally, for example as an audio clip, and the statement itself must be accessible.
  • The EAA says it belongs in your terms and conditions or an equivalent document. The Dutch regulator, the ACM, says to put it on your website and app, easy to find.
  • The Dutch government statement, with statuses A to E and a public register, is for government bodies. Businesses don't use that model or register.

What does the EAA require?

Three pieces of content, in two formats, kept for as long as your service runs. This comes from Article 13 and Annex V of the EAA, Directive (EU) 2019/882. It applies to the services the EAA covers, such as online shops and consumer banking. Micro-enterprises are exempt.

The statement must contain, "where applicable":

  1. A general description of the service, in accessible formats.
  2. The descriptions and explanations needed to understand how the service works.
  3. A description of how the service meets the accessibility requirements in the EAA.

On top of that:

  • It must be available "in written and oral format", and in a way that's accessible to people with disabilities.
  • You must keep it for as long as the service is in operation.
  • You must be able to show that the way you deliver and monitor your service keeps it compliant.

The ACM adds a few practical points for Dutch online shops and telecom services:

  • Explain how your service works with assistive technology, such as screen readers.
  • Give information about the accessibility of the products or services you sell, where relevant.
  • Your customer service or helpdesk must be able to give information about the accessibility of your service.

Belgium's law adds one nuance worth copying everywhere: you explain whether your service does "or does not" meet the requirements. In other words, a statement isn't only for good news.

Where do I publish it?

On your website and in your app, where people can find it easily, and linked from your terms and conditions. The sources say slightly different things, so doing both is the safe route:

Source Where it says the statement goes
EAA (Annex V) "In the general terms and conditions, or equivalent document"
Belgian law The same: in the general terms and conditions or an equivalent document
ACM (Netherlands) "On your website and app", "easy-to-find for consumers", and accessible
Ondernemersplein (Dutch government business portal) On your website or app, easy for visitors to find

A common setup is a page called "Accessibility" linked from the footer of every page, a link to it from your terms and conditions, and the same text in your app's settings or help section.

The oral version. The ACM says the statement "must also be offered verbally, for example in an audio clip with the text read aloud". An audio file of the statement on the same page is the simplest way to do that.

What should I put in it?

Describe your service, how it works for people using assistive technology, and where it does and doesn't meet the requirements. There's no official EU template for businesses, and we found no ACM template either. Here's a structure that covers the legal content, in plain words. The headings are our suggestion, not a legal requirement.

Section What to write Covers
About this service What your site or app does: browse products, order, pay, track deliveries, manage your account General description
How it works The main steps, and how to use them with a keyboard, screen reader or zoom. Mention alternatives, like ordering by phone Explanation of how the service works
Accessibility standard That you aim to meet the international accessibility standard, WCAG, at level AA, and how you checked it (for example, a review on a given date) How the requirements are met
What doesn't work yet Known problems, who they affect, and when you expect to fix them How the requirements are (or aren't) met
How we keep it accessible How you test new features and content, and how often you review the site Delivery and monitoring
Product information Where relevant, accessibility information about the products you sell ACM guidance for online shops
Contact How to report a problem or get help, including a non-web option like phone or email Customer service information
Date When the statement was last updated Keeping it current

Two practical tips:

  • Keep it honest. If you've reported problems to the ACM under the Dutch reporting duty, your statement shouldn't claim the site is fully accessible. See our guide on the ACM reporting duty.
  • Keep it current. Update it when you fix problems, launch new features or test the site again.

How is it different from the Dutch government statement?

They're two different documents under two different laws. If you search for "toegankelijkheidsverklaring", most Dutch results are about the government version. Don't copy it as a business.

Government statement Business statement (EAA)
Law Web Accessibility Directive (EU) 2016/2102, Dutch decree on digital accessibility for government European Accessibility Act, Directive (EU) 2019/882
Who Government bodies Businesses offering covered services to consumers, except micro-enterprises
Template Fixed model, filled in with the government's online assistant No official template
Status label A (fully compliant) to E (no statement) None
Public register Yes, the register of accessibility statements No
Audit needed For status A or B, a full audit less than 3 years old No audit or certificate required, according to the ACM
Where On the website, or at the app download Terms and conditions or equivalent (EAA); website and app (ACM)
Format Fixed model Written and oral, accessible
Known problems Listed in the statement Reported to the ACM when you can't fix them in time

Anyone can create an account in the government's statement tool, but only statements from government bodies are published in the register.

What to do next

  1. Check that the EAA applies to you. Micro-enterprises don't need a statement under the EAA.
  2. Find out where your site actually stands, so the statement is accurate. An accessibility review gives you a dated basis to write from.
  3. Write the statement using the structure above, and have someone outside your team read it for clarity.
  4. Publish it on an "Accessibility" page linked from every page and from your terms and conditions. Add an audio version.
  5. Set a reminder to update it after fixes, redesigns or new tests.

FAQ

Do I need a statement if my site is fully accessible?

Yes. The statement isn't a confession of problems. It's information on how your service meets the requirements, and it's required either way.

Can I use the Dutch government template?

You can borrow ideas from it, but it was made for a different law and doesn't follow the EAA's list of content. Its A to E status and register are for government bodies only.

Does the statement need to be in Dutch or French?

The EAA doesn't set a language. Our advice: write it in the language or languages your customers use for your service.

Do I need an audit before I write it?

The ACM says an audit isn't mandatory. But the statement has to explain how you meet the requirements, which is hard to do accurately without testing your site.

Sources

  1. Directive (EU) 2019/882, Article 13 and Annex V · EUR-Lex
  2. Accessibility of e-commerce services and electronic communications services · ACM
  3. Toegankelijkheid van e-handelsdiensten en elektronische communicatiediensten · ACM
  4. Regels voor digitale toegankelijkheid van producten en diensten · Ondernemersplein
  5. Burgerlijk Wetboek Boek 6, article 230fb · wetten.overheid.nl
  6. Wet van 5 november 2023 (Belgisch Staatsblad) · Belgian Official Gazette
  7. Tijdelijk besluit digitale toegankelijkheid overheid · wetten.overheid.nl
  8. Status van de toegankelijkheidsverklaring · DigiToegankelijk
  9. Toegankelijkheidsverklaring · DigiToegankelijk
  10. Commission Implementing Decision (EU) 2018/1523 (model statement for the public sector) · EUR-Lex