Accessibility statements under the EAA: what Annex V asks for, with a template

The European Accessibility Act does not ask for an accessibility statement by that name. It asks a service provider to publish information: the content Annex V lists, explaining how the service meets the accessibility requirements, placed in the general terms and conditions or an equivalent document, and made public in written and oral format (Article 13(2) and Annex V).

No form is prescribed. The template in this post is a suggested layout of that information, with the fields only you can decide left blank. It is a guide to the Directive, not legal advice: check the law of each country where you provide the service.

Our guide to the European Accessibility Act and your website covers the rest of what the Act asks, from its articles to the tests you run.

What the Act asks a service to publish

Article 13(2) of Directive (EU) 2019/882 holds the whole obligation in three sentences. Service providers “shall prepare the necessary information in accordance with Annex V and shall explain how the services meet the applicable accessibility requirements.” The information “shall be made available to the public in written and oral format, including in a manner which is accessible to persons with disabilities.” And they “shall keep that information for as long as the service is in operation.”

Annex V says what the information is. Point 1 asks for “the information assessing how the service meets the accessibility requirements”, describing the requirements that apply and covering the design and operation of the service as far as they matter for that assessment. Where applicable, it contains:

• (a) a general description of the service in accessible formats;
• (b) the descriptions and explanations needed to understand how the service operates;
• (c) a description of how the service meets the relevant accessibility requirements of Annex I.

Two more points complete it. Point 2 lets you apply, in full or in part, harmonised standards and technical specifications whose references are published in the Official Journal; no harmonised standard is cited under the Act yet, so you describe how the service meets Annex I, and you can name the standard you tested against. Point 3 asks for information “demonstrating that the service delivery process and its monitoring ensure compliance”: how you keep the service accessible, not only how it stands today.

This comes on top of the consumer information you already give under the Consumer Rights Directive (Directive 2011/83/EU), which Annex V and recital 81 both name. The word “statement” does not appear anywhere in the Directive. You can still call your page an accessibility statement, and nothing in the Directive stops you; what the Act asks about is the content and where it sits.

Article 4(5) exempts micro-enterprises providing services from the service requirements and from “any obligations relating to the compliance with those requirements”; check how your national law applies that to this duty. If you are not sure the Act reaches you at all, check first whether the Act covers your service.

Where the information goes

Annex V names the place: the general terms and conditions, or an equivalent document. Two ways fit that wording.

• In the terms themselves. A section of your terms and conditions holds the information. It is exactly where the Act points, but terms are long, and someone looking for accessibility help rarely starts there.
• On its own page, referred to from the terms. An accessibility page holds the information, the terms refer to it, and your footer links to it from every page. Whether that page counts as an “equivalent document” is for your national law; a reference from the terms means the terms still lead to it.

Wherever it sits, the information has to be accessible itself. Article 13(2) says so, and Annex I asks that information about how a service works be available “via more than one sensory channel”, in text formats that can be turned into other formats, in fonts of adequate size and suitable shape, with sufficient contrast and adjustable spacing, and with an alternative for non-text content (Section III(b)). An image-only PDF of your terms does not meet that.

Written and oral

The Directive asks for the information “in written and oral format” and does not define oral format; your national law or your authority may. Some ways to provide it, offered as practical suggestions rather than a reading of the law:

• a phone line or support channel whose staff can read the information out and answer questions about it. Annex I already asks that support services, where you have them, give information on the service’s accessibility and its compatibility with assistive technologies “in accessible modes of communication” (Section III(d));
• a recorded audio version of the page, revised whenever the text is;
• a line on the page itself saying the information can be read out on request, with the number and when it is answered.

For as long as the service runs

The Act sets no review interval, but Article 13(3) asks for procedures that keep the service in conformity and take account of changes to the service, to the requirements and to the standards. A redesign, a new checkout or payment provider, or a newly cited standard is a reason to revise the text. Dating each revision shows readers which version of the service it describes.

If you rely on Article 14

Article 14 lets the requirements give way where meeting them would fundamentally alter the service or impose a disproportionate burden. Relying on it is a process with its own records, and most of them are not public. You make the assessment, weighing a burden against the criteria in Annex VI. You document it, keep the results for five years after you last provide the service, and give the authority a copy on request (14(3)). You cannot rely on a disproportionate burden if you receive outside funding to improve accessibility (14(6)). You renew a burden assessment when the service changes, when the authority asks, and at least every five years (14(5)). And, unless you are a micro-enterprise, you send information that you rely on it to the authority where you provide the service (14(8)).

Annex V does not ask you to publish the assessment. Saying in the public information that you rely on Article 14 for part of the service, with the alternative you offer, tells people what to expect; the template has an optional section for it, left blank. Check whether your national law expects it there.

A known gap is a different matter. If the service does not meet a requirement and Article 14 does not cover it, Article 13(4) asks for the corrective measures needed and for you to “immediately inform” the national authorities of the member states where you provide the service, with details of the gap and what you are doing about it. Listing the gap on your accessibility page does not replace that report.

A template for the Annex V information

Below is a suggested layout. It is not an official form: neither the Directive nor the Danish act prescribes one for a private service, and your national law may ask for more. Each section is commented with the point of Annex V or the article it serves:

• The service: Annex V point 1(a), a general description.
• How to use it: point 1(b).
• How the service meets the requirements: point 1 (the requirements that apply) and 1(c), including the standard you evaluated against. Point 2 lets you rely on a harmonised standard or technical specification once one is cited.
• Known limitations: part of an honest answer to 1(c); see Article 13(4) above. Article 2(4) takes some content out of scope, such as third-party content you neither fund, develop nor control and office files published before 28 June 2025; say what is excluded and why.
• Assessment under Article 14: only if you rely on it.
• How we keep the service accessible: point 3 and Article 13(3).
• Contact us: a route to the information in oral and accessible formats (Article 13(2)), and a way to report a barrier.
• Dates: not required by Annex V, but they show which version of the service the text describes.

Three fields are marked [DECIDE] and offer no options: your conclusion against the standard, how you evaluated it, and the outcome of any Article 14 assessment. They are your declarations, and the next section explains what goes into them.

<!--  Accessibility information for [service name].  A suggested layout of the information Annex V of Directive (EU) 2019/882  lists. It is not an official form: check the law of each country where  you provide the service. Replace every [bracket].  [DECIDE] marks a declaration only you can make. Leave it empty until you  have made it, or remove the section.--><section aria-labelledby="accessibility-information">  <h2 id="accessibility-information">Accessibility of [service name]</h2>  <p>    First published <time datetime="[YYYY-MM-DD]">[date]</time>.    Last revised <time datetime="[YYYY-MM-DD]">[date]</time>.  </p>​  <!-- Annex V 1(a): a general description of the service -->  <h3>The service</h3>  <p>[What the service is, who it is for, and where it is provided:     website, app, phone, shop.]</p>​  <!-- Annex V 1(b): what someone needs to understand how it operates -->  <h3>How to use it</h3>  <p>[The main tasks, step by step: find a product, pay, track an order,     cancel. Name any step that needs an account, a one-time code or a     payment page run by another company.]</p>​  <!-- Annex V point 1 (the applicable requirements) and 1(c). Point 2 applies once a harmonised standard or technical specification is cited in the Official Journal; none is yet. -->  <h3>How the service meets the accessibility requirements</h3>  <p>Requirements: [the accessibility requirements of (your national law     transposing Directive (EU) 2019/882) that apply to this service].</p>  <p>Standard we evaluated against: [standard, version and level].</p>  <p>Accessibility features: [for example keyboard use, text alternatives,     captions, zoom and reflow, a choice of payment methods].</p>  <p>Our conclusion against that standard: [DECIDE]</p>  <p>How we evaluated it: [DECIDE]</p>​  <!-- Part of an honest 1(c). A gap also triggers Article 13(4). -->  <h3>Known limitations</h3>  <ul>    <li>[Where, what does not work and for whom, the alternative we offer,        and when we expect to fix it.]</li>  </ul>​  <!-- Only if you rely on Article 14 with a documented assessment.       Otherwise delete this section. -->  <h3>Assessment under Article 14</h3>  <p>[DECIDE]</p>​  <!-- Annex V point 3 and Article 13(3): delivery and monitoring -->  <h3>How we keep the service accessible</h3>  <p>[Who checks accessibility when the service changes, against which     standard, how often, and what happens to a defect once found.]</p>​  <!-- One way to offer the oral format Article 13(2) asks for; check what your national authority accepts -->  <h3>Contact us</h3>  <p>To have this information read to you, to get it in another format,     or to report a barrier: [email address], [phone number and when it     is answered], [postal address].</p></section>

The same layout in Markdown, for a CMS or a terms document written in Markdown:

<!--  Accessibility information for [service name]: a suggested layout of the  Annex V information, not an official form. Check your national law.  [DECIDE] marks a declaration only you can make.-->​## Accessibility of [service name]​First published [date]. Last revised [date].​### The service<!-- Annex V 1(a) -->[What the service is, who it is for, and where it is provided.]​### How to use it<!-- Annex V 1(b) -->[The main tasks, step by step, and any step that needs an account,a one-time code or another company's payment page.]​### How the service meets the accessibility requirements<!-- Annex V point 1 (the applicable requirements) and 1(c). Point 2 applies once a harmonised standard or technical specification is cited in the Official Journal; none is yet. -->- Requirements: [the requirements of your national law that apply]- Standard we evaluated against: [standard, version and level]- Accessibility features: [the features a disabled customer can rely on]- Our conclusion against that standard: [DECIDE]- How we evaluated it: [DECIDE]​### Known limitations<!-- Part of an honest 1(c); a gap also triggers Article 13(4) -->- [Where, what does not work and for whom, the alternative, the fix date]​### Assessment under Article 14<!-- Only with a documented assessment; otherwise delete -->[DECIDE]​### How we keep the service accessible<!-- Annex V point 3 and Article 13(3) -->[Who checks, against what, how often, and what happens to a defect.]​### Contact us<!-- One way to offer the oral format Article 13(2) asks for; check what your national authority accepts -->To have this information read to you, to get it in another format, or toreport a barrier: [email address], [phone number and when it is answered],[postal address].

Filling in the fields you decide

• Your conclusion against the standard. Name the standard, its version and the level, then state your own conclusion in your own words. Annex V gives no status options, unlike the public-sector model below, and a list of what works and what does not tells a reader more than one borrowed label.
• How you evaluated it. Say what was done: who tested, when, which pages and journeys, which tools, and whether people tested with assistive technologies. An automated scan, ours included, is one input to your own evaluation. It is not an evaluation of the whole service, and it cannot decide criteria that need a person’s judgement. Our guide to scoping and sampling an accessibility audit covers how to choose what to test.
• Assessment under Article 14. Fill it in only from a documented assessment, as described above. A sentence that sounds reasonable without an assessment behind it is worse than an empty field.

Public-sector statement or Annex V information

Many of the statement templates you will find follow the public sector’s model: the one the Commission set for the Web Accessibility Directive (Directive (EU) 2016/2102) in Implementing Decision (EU) 2018/1523. It is a different instrument with a different job.

• Who it is for. Web Accessibility Directive: public sector bodies’ websites and apps. EU Act: providers of the listed services to consumers, except micro-enterprises.
• What the law calls it. Web Accessibility Directive: an “accessibility statement”. EU Act: “information”; it never says “statement”.
• Form. Web Accessibility Directive: the Commission’s model, at least its mandatory content. EU Act: none set; Annex V lists elements “where applicable”.
• A verdict. Web Accessibility Directive: one of three statuses from the model, quoted below. EU Act: no status field; you explain how the service meets the requirements.
• The evidence behind it. Web Accessibility Directive: the statement names its method, a self-assessment, a third-party assessment, or other measures giving equal assurance. EU Act: information showing that your delivery process and monitoring keep the service meeting the requirements (Annex V point 3).
• Where it goes. Web Accessibility Directive: on the website, linked from the home page or from every page. EU Act: in the general terms and conditions or an equivalent document, public in written and oral format.
• Feedback and enforcement. Web Accessibility Directive: a feedback mechanism, and a link to the enforcement procedure (Article 7(1)). EU Act: not part of Annex V; national procedures follow up complaints, and consumers can act under national law (Articles 23 and 29).
• Disproportionate burden. Web Accessibility Directive: the content it covers is listed in the statement. EU Act: you document the assessment and notify the authority (Article 14(3) and 14(8)); Annex V does not ask you to publish it.
• Review. Web Accessibility Directive: the model recommends a review at least once a year. EU Act: no interval; you take changes into account (Article 13(3)) and keep the information while the service runs.

Denmark: two laws, two routes

Denmark shows how far apart the two regimes can sit.

• Public bodies publish a statement under the web accessibility act (webtilgængelighedsloven). The Agency for Digital Government (Digitaliseringsstyrelsen) requires it to be made in its WAS-Tool, reachable at a standard address on was.digst.dk, linked from the site’s footer where practicable, and updated at least once a year.
• Private services under the EU Act follow LOV nr 801 of 7 June 2022, as amended, the act on accessibility requirements for products and services (tilgængelighedsloven). Its § 35 is Article 13(2) in Danish, with one addition: the provider prepares the information before it provides the service. Its bilag 4 is Annex V, place included: “i de almindelige betingelser eller et tilsvarende dokument”.
• No separate statement. The Danish Business Authority (Erhvervsstyrelsen), which supervises e-commerce services, said in its June 2026 presentation on the act that “Tilgængelighedsloven stiller ikke krav til særskilt tilgængelighedserklæring”: the private-sector act asks for no separate accessibility statement, unlike the public-sector one. The obligation is the § 35 information. The same presentation names EN 301 549 and WCAG 2.2 as how services best meet the requirements in practice.
• WAS-Tool is closed to you. Digitaliseringsstyrelsen says private actors may not use WAS-Tool to publish statements. They may write their own, as long as it cannot be confused with one made in WAS-Tool.

For a Danish shop, then, the template above is one way to lay out the § 35 information, in the terms or an equivalent document (bilag 4), with a written and an oral route, ready before the service is offered.

Other member states transpose Article 13(2) in their own words, and some authorities publish their own guidance or templates. Check the law of each country where you provide the service, and its authority’s guidance, before you rely on any template, ours included.

Before you publish

• The information sits in your terms or an equivalent document. We also suggest a footer link to it, so people can find it from every page.
• Every [DECIDE] field holds your own declaration, and the Article 14 section is gone if you do not rely on it.
• The page itself meets the standard it names: headings, link text, contrast, and a text version of anything you add as audio.
• The oral route works, and the people who answer it know the page.
• Each revision is dated, and a change to the service starts a review.
• If you rely on Article 14, the notice to the authority has gone out separately.

The page is information about your service, and EN 301 549 has clauses for that kind of information and for support documentation as well as for web pages. We list them in our map of the EN 301 549 clauses for a website.

To see where one of your pages stands before you write the requirements section, scan one page of your site: the free scan needs no sign-up and shows real findings from that page.