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Your Accessibility Statement according to EAA – Guide & Template

Portrait of Dmitry Dugarev wearing glasses in a black shirt and smiling

Dmitry Dugarev

Consultant for digital accessibility & IT compliance

Your Accessibility Statement according to EAA – Guide & Template

The European Accessibility Act (EAA) has entered into force, and the deadline for implementing digital accessibility for many products and services expired on June 28, 2025 according to § 1 (2) and (3) EAA [1]. This also applies to your website or app if you operate in the B2C sector—that is, if you offer electronic commerce services.

A central component of this obligation is the accessibility statement. It is essentially the official certificate of your website regarding its accessibility. But don't worry, it's not magic!

In this article, I will show you step by step:

  • Why you need an accessibility statement.
  • Exactly what needs to be included.
  • How to create it—regardless of whether your site is already perfect or still has issues.
  • Templates you can use directly.

Let's get started!

Why do I need an accessibility statement?​

Simply put: Because the law requires it.

The EAA stipulates in § 14 ("Obligations of the Service Provider") [1] that, as a provider of a service (which includes websites in electronic commerce according to § 1 (3) No. 5 and § 2 No. 26 EAA [1]), you must provide information on how your service meets the accessibility requirements (§ 14 (1) No. 1 EAA [1]).

More specifically, § 14 (1) No. 2 EAA [1] states that you must prepare information according to Annex 3 No. 1 EAA [1] and make it accessible.

And what exactly is in this ominous Annex 3?

The service provider shall indicate regarding their service [...] in their General Terms and Conditions or in another clearly noticeable way how it meets the accessibility requirements [...] (Annex 3 No. 1 Sentence 1 EAA [1])

This indication of how the requirements are met – that is your accessibility statement! It is therefore not a kind gesture, but a legal obligation since June 28, 2025. It creates transparency for your users and the responsible authorities.

What MUST be included in the statement? (The mandatory components)​

Okay, duty understood. But what exactly needs to be included? Annex 3 EAA [1] and common practice give us a clear structure. Your statement requires at least these sections:

  1. Scope: Which website(s) or app(s) does this statement apply to? Name the exact URL(s).
  2. A general description of the service in an accessible format: Describe your service so that it is understandable to all users, including people with disabilities, or refer to your GTC if the description is located there.
  3. Legal Basis: Which laws and standards are you referring to? (Tip: EAA and EN 301 549).
  4. Compliance Status: How well does your site meet the requirements? Is it conformant, partially conformant, or not conformant?
  5. (Optional, but usually necessary) Non-accessible content: If your site is only partially or not conformant: Which areas or content are not and why? Are there accessible alternatives?
  6. Feedback Mechanism: How can users report barriers to you? Provide clear contact methods (email, form, etc.).
  7. Enforcement/Dispute Resolution Procedure: Who can users contact if they are dissatisfied with your response to their feedback? (Note: This is the competent market monitoring body).
  8. Date of Creation: When was the statement created or last updated?

Step-by-Step Guide to the Accessibility Statement​

Let's go through the sections individually.

Scope​

  • What: Clearly state which digital presence this statement applies to.
  • How: Name the exact URL(s) of your website(s) or the name and platform of your app(s). Also state who the operator is (Your name/company name).

This accessibility statement applies to the website https://www.your-domain.de, operated by [Your Name/Your Company].

Description of the Service​

  • What: Briefly describe what your website or app does.
  • How: Summarize the core functionalities and purpose of your digital service in simple words. Alternatively, you can refer to your GTC if a detailed description is provided there.

[Your domain] is an online shop that offers a wide range of products in the areas of electronics, household, and leisure. Our platform allows customers to browse, compare, and securely purchase products online. More information about our services can be found in our General Terms and Conditions.

  • What: Name the laws and technical standards you adhere to.
  • How: Refer to the EAA [1] and the harmonized standard EN 301 549 [2], to which § 4 EAA [1] refers. Since EN 301 549 is based on the WCAG [3], you should also name the WCAG version and conformance level you aim for (currently, WCAG 2.2 A & AA [4] is recommended).

We endeavor to design our website to be accessible in accordance with the European Accessibility Act (EAA) and the harmonized European standard EN 301 549 V3.2.1 (based on WCAG 2.1 A & AA), which establishes a presumption of conformity according to § 4 EAA. The goal is to meet the Web Content Accessibility Guidelines (WCAG) 2.2 at Conformance Level AA.

Compliance Status​

  • What: Honestly assess how well your website meets the requirements of WCAG (A & AA). It is best to book an accessibility audit or perform a self-test using our EAA checklist.
  • How: This is the tricky part. You must perform an assessment. The result is a classification:
    • Conformant: All criteria are met. Great!
    • Partially conformant: Most criteria are met, but there are known exceptions/barriers.
    • Not conformant: Many criteria are not met.

Open textual description for "Flowchart: Evaluation of Compliance with WCAG 2.2 A/AA"

This flowchart describes the process for evaluating compliance with the WCAG 2.2 A/AA criteria.

  1. The process begins with performing an evaluation (A), either through a professional audit or a self-assessment.
  2. Then it is checked (B) whether all 55 WCAG 2.2 A/AA criteria are met.
    • If Yes, the website is rated as Compliant (C).
    • If No, but more than 50% of the criteria are met, the website is rated as Partially compliant (E).
    • If No, the website is rated as Not compliant (D).

Formulate the status clearly and state how you determined it (e.g., self-assessment). Then use one of the following templates to formulate the section:

This website is fully conformant with the requirements of WCAG 2.2 Level A and AA. The assessment was carried out by an internal self-assessment on [Date].

Non-accessible content (Only for partially/not conformant status)​

  • What: If you are not (fully) conformant, you must name the known barriers. List the known barriers.
  • How:
    • Be specific: Which content or functions are affected? (e.g., "PDF documents", "Video subtitles", "Contrast in the footer").
    • Provide reasons (optional, but good): Why is it (still) not accessible? (e.g., "technical limitation", "currently being revised"). Mention whether a disproportionate burden according to § 17 EAA [1] was examined, if applicable.
    • Offer alternatives: Is there another way to get the information? (e.g., "Contact us for an accessible version", "The core information can also be found on page X").

The following content is not yet fully accessible for the reasons stated:

  • PDF Documents: Our older brochures (before 2024) are not tagged and are therefore difficult for screen readers to access. Alternative: The content can also be found on the respective product pages. We are working on creating new accessible PDFs.
  • Product Configurator: Keyboard operation is not yet optimal in step 3. Alternative: Please contact our support; we will gladly assist you with the configuration. A revision is planned for Q1/2026. Achieving full accessibility would currently constitute a disproportionate burden according to § 17 EAA, which has been documented.
  • Some Videos: Videos published before June 28, 2025 (see § 1 (4) No. 1 EAA) may not have subtitles or audio descriptions. New videos will be produced accessibly.

Feedback Mechanism​

  • What: Offer users an easy way to report barriers to you. This is also relevant for the procedure with the market monitoring body according to § 32 EAA [1].

  • How: Name at least one clear contact option (email address, contact form link). Briefly describe what users should report.

Have you noticed any deficiencies in the accessible access to content on https://www.your-domain.de? Or do you have questions about accessibility? Please contact us:

  • Email: [your-feedback-email@your-domain.de]

  • Contact Form: [Link to your contact form]

    Please describe the problem as accurately as possible and specify the affected webpage (URL). We endeavor to process your request promptly.

Enforcement/Dispute Resolution Procedure​

  • What: Inform users who they can contact if your feedback process was unsatisfactory. This refers to the dispute resolution procedure according to § 34 EAA [1] and the procedure with the market monitoring body (see Sections 7 and 8 EAA [1]).

  • How: Name the competent market monitoring body for digital accessibility. In Germany, since September 26, 2025 [5], this is centrally the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF). Provide their contact details (Name, Address, Email/Website).

If you have not received a satisfactory answer to your inquiry via our feedback contact within a reasonable period (usually four weeks), you can contact the competent market monitoring body.

Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF)

You may also consider the dispute resolution procedure according to § 34 EAA.

Date of Creation​

  • What: State when the statement was created and/or last reviewed and updated.

  • How: A simple sentence at the end is sufficient.

This statement was created on [Date of Creation] and last reviewed on [Date of last Update].

Templates for Your Accessibility Statement​

Here are two samples you can use as a base. Replace the placeholders [...] with your information.

Template: Conformant
This accessibility statement applies to the website [Link zu Deiner Website], operated by [Dein Name/Deine Firma].

## Description of the Service

[Your Domain] is a [...], where we [short description of the services]. More information about our services can be found in our [General Terms and Conditions](https://www.your-domain.de/agb).

## Legal Basis

We endeavor to design our website to be accessible in accordance with the European Accessibility Act (EAA) and the harmonized European standard EN 301 549 V3.2.1 (based on WCAG 2.1 A & AA), which establishes a presumption of conformity according to § 4 EAA. The goal is to meet the Web Content Accessibility Guidelines (WCAG) 2.2 at Conformance Level AA.

## Compliance Status with the Requirements

This website is **fully conformant** with the requirements of WCAG 2.2 Level A and AA.

The assessment was carried out by [Method, e.g., an internal self-assessment / an external audit by Company XY] on [Date of Assessment].

## Feedback and Contact Information

Have you noticed any deficiencies in the accessible access to content on [Link zu Deiner Website]? Or do you have questions about accessibility? Please contact us:

- **Email:** [Your feedback E-Mail]
- **Contact Form:** [Link to your contact form]

Please describe the problem as accurately as possible and specify the affected webpage (URL).

## Enforcement Procedure

If you have not received a satisfactory answer to your inquiry via our feedback contact within a reasonable period (usually four weeks), you can contact the competent market monitoring body (see § 32 EAA).

**Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF)**

- **Address:**
  MLBF
  c/o Ministerium für Arbeit, Soziales, Gesundheit und Gleichstellung Sachsen-Anhalt
  Postfach 39 11 55
  39135 Magdeburg
- **Phone:** [+49 391 567 6970](tel:+493915676970)
- **Email:** [MLBF@ms.sachsen-anhalt.de](mailto:MLBF@ms.sachsen-anhalt.de)

You may also consider the dispute resolution procedure according to § 34 EAA.

## Creation of this Statement

This statement was created on [Date of Creation] and last reviewed on [Date of last Update].

Use these templates as a starting point and adapt them to your specific situation. Remember to regularly review and update the statement, especially when you make changes to your website or achieve progress in accessibility.

Conclusion: More than just a mandatory exercise​

While the accessibility statement is legally required according to § 14 (1) No. 2 EAA in conjunction with Annex 3 No. 1 EAA [1], it is much more than that:

  • It is a commitment to inclusion.
  • It creates transparency for your users.
  • It gives you a framework to document your progress.
  • It is an important step towards legal certainty under the EAA.

Create your statement carefully, keep it current, and – most importantly – continuously work on reducing barriers on your website. Your users will thank you!

Frequently Asked Questions (FAQ) about the Accessibility Statement​

Here you will find answers to some common questions regarding the accessibility statement under the EAA:

What exactly is an accessibility statement?​

The accessibility statement is an official document or webpage in which you, as a provider, explain the extent to which your website or app meets the legal requirements for digital accessibility. It is mandatory according to § 14 (1) No. 2 in conjunction with Annex 3 No. 1 EAA [1] and serves transparency towards users and authorities.

Who needs an accessibility statement under the EAA?​

In principle, all providers of products and services that fall under the scope of the EAA (see § 1 (2) and (3) EAA [1]) require such a statement for their digital interfaces (websites, apps). This particularly affects providers in the B2C sector, e.g., online shops (§ 1 (3) No. 5 and § 2 No. 26 EAA [1]), banking services (§ 1 (3) No. 3 EAA [1]), passenger transport services (§ 1 (3) No. 2 EAA [1]), and telecommunication services (§ 1 (3) No. 1 EAA [1]).

Exception: Micro-enterprises (fewer than 10 employees and max. 2 million € annual turnover/balance sheet total, see § 2 No. 17 EAA [1]) that offer services are exempt from the accessibility requirements, and thus the statement obligation, according to § 3 (3) EAA [1]. However, this exception does not apply to micro-enterprises that manufacture or distribute products!

Is the statement truly mandatory? What happens if I don't have one?​

Yes, the statement is mandatory (§ 14 (1) No. 2 EAA [1]). If you do not provide a (correct) statement, this constitutes formal non-conformity (§ 30 (2) EAA [1]). The competent market monitoring body (MLBF) can then request you to create or correct the statement (§ 30 (1) EAA [1]). If you fail to comply, further measures, up to prohibiting the offering of your service, may follow (§ 30 (3) and (4) EAA [1]). Furthermore, fines may be imposed (see § 37 EAA [1]).

Does my website have to be perfectly accessible to create the statement?​

No. The statement should reflect the actual state of accessibility. That is why there are the statuses "partially conformant" or "not conformant". It is important that you are honest and, in the event of deficiencies, name them transparently in the statement (section "Non-accessible content"). The statement itself is mandatory even if your site is not yet fully accessible.

Where should I place the statement on my website?​

The law (§ 14 (1) No. 2 in conjunction with Annex 3 No. 1 Sentence 1 EAA [1]) allows the information to be included in the GTC "or in another clearly noticeable way". The most common and user-friendly method is a separate, dedicated webpage clearly titled "Accessibility Statement" and easily discoverable (e.g., via a link in the footer).

Is a self-assessment sufficient for the compliance status?​

Yes, for the creation of the statement itself, a self-assessment is permissible. You are not legally obliged to have an external audit conducted just to write the statement. However: A thorough self-assessment requires specialist knowledge. If you are unsure or want a more reliable status, an ** external audit** by experts (as we offer here) is strongly recommended. The result of an audit gives you more certainty about the actual status.

What is the difference between EN 301 549 and WCAG?​

EN 301 549 is the harmonized European standard to which the EAA indirectly refers via § 4 [1] to define the technical requirements. This standard, in turn, includes and references the Web Content Accessibility Guidelines (WCAG) in its chapters on web content. Currently, the valid EN 301 549 V3.2.1 [2] is based on WCAG 2.1 AA. However, since WCAG 2.2 [4] is the newer standard and the EN standard will soon be updated, it makes sense to orient yourself directly towards WCAG 2.2 AA.

What does "disproportionate burden" mean?​

The EAA stipulates in § 17 [1] that accessibility requirements only apply insofar as their compliance does not constitute a disproportionate burden for the provider. However, this is a strict exception, not a general excuse! You must carry out a detailed assessment based on the criteria in Annex 4 EAA [1] (cost-benefit analysis, financial resources, etc.) and document this. The market monitoring body can check this assessment (§ 21 (3), § 28 (3) EAA [1]). If you rely on this, you must state it in the accessibility statement and document the assessment (§ 17 (2) and (3) EAA [1]).

How often must I update the statement?​

The law does not prescribe a fixed rhythm. However, it is best practice and necessary for transparency to update the statement when essential things change:

  • After major website relaunches or function updates.
  • If you have made significant improvements in accessibility.
  • If new assessments (audits, self-tests) have been carried out.
  • At least once a year to ensure the timeliness of the information (especially the date).

What is the MLBF and what does it do?​

The MLBF (Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen, or Market Monitoring Body of the States for the Accessibility of Products and Services) is the central authority in Germany responsible for monitoring compliance with the EAA. It randomly checks whether products and services (including websites) are accessible (§ 28 EAA [1]), investigates user complaints (§ 32 EAA [1]), and can take measures if providers do not meet the requirements (§ 29, § 30 EAA [1]). It is also the body that users can contact if they cannot find a satisfactory solution through your feedback channel (§ 32, § 33 EAA [1]).

Disclaimer​

This article is for informational purposes only and does not constitute legal advice. For specific legal questions regarding the EAA and accessibility statements, please consult a qualified legal professional.

​

  1. Bundesministerium der Justiz und für Verbraucherschutz, “Gesetz zur Umsetzung der Richtlinie (EU) 2019/882 des Europäischen Parlaments und des Rates über die Barrierefreiheitsanforderungen für Produkte und Dienstleistungen (Barrierefreiheitsstärkungsgesetz – BFSG).” 2023. [Online]. Available: https://www.gesetze-im-internet.de/bfsg/ ⤴
  2. ETSI, “ETSI EN 301 549 V3.2.1 (2021-03) - Accessibility requirements for ICT products and services.” 2021. [Online]. Available: https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf ⤴
  3. W3C Web Accessibility Initiative, “WCAG 2.2 Overview.” 2023. [Online]. Available: https://www.w3.org/WAI/standards-guidelines/wcag/wcag2.2/ ⤴
  4. W3C, “Web Content Accessibility Guidelines (WCAG) 2.2.” 2023. [Online]. Available: https://www.w3.org/TR/WCAG22/ ⤴
  5. Landesportal Sachsen-Anhalt, “Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen.” 2025. [Online]. Available: https://ms.sachsen-anhalt.de/themen/menschen-mit-behinderungen/aktuelles/marktueberwachungsstelle-der-laender-fuer-die-barrierefreiheit-von-produkten-und-dienstleistungen ⤴
Portrait of Dmitry Dugarev wearing glasses in a black shirt and smiling

Best regards,

Dmitry Dugarev

Founder of Barrierenlos℠ and developer of the Semanticality™ plugin. With a master’s degree, over 8 years of experience in web-development & IT-Compliance at Big Four, Bank and Enterprise, and more than 1,000 web pages tested for accessibility for over 50 clients, I help web teams implement accessibility in a structured way — without months of redevelopment.

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