Accessibility statements: what has to be in one
Public sector bodies in the EU must publish an accessibility statement with a feedback mechanism. What the required sections are, and why a copied template is worse than none.
Web accessibilityPublished
The accessibility statement is a requirement of the Web Accessibility Directive, (EU) 2016/2102, for public sector bodies. The Commission set out a model in an implementing decision, and member states have their own national templates built on it. If you run a public sector website in the EU, you need one, it needs to be findable, and it needs to be accurate.
Private sector organisations under the European Accessibility Act have a related but different obligation: information about how the service meets the accessibility requirements has to be provided, in an accessible way, in the general terms and conditions or an equivalent document. It is not called an accessibility statement and it is not the same document, though in practice many organisations publish something statement-shaped to cover it.
The required parts
A conforming statement has a fixed skeleton.
A compliance status. One of three values, and the wording is deliberate: fully compliant, partially compliant, or non-compliant. Partially compliant is the honest answer for most sites and is a perfectly acceptable status. There is no penalty attached to admitting it; there is exposure attached to claiming full compliance and being wrong.
A list of non-accessible content. Each item has to say what is inaccessible, which requirement it fails, and why. “Why” has three legitimate categories: the requirement is not met yet, the content falls outside the scope of the directive, or meeting it would be a disproportionate burden. If you claim disproportionate burden, you have to have done the assessment.
A feedback mechanism. A way for anyone to report a barrier or request content in an accessible format, and a commitment to respond. This is the part users actually use, and it is the part most often broken. An address that bounces is a compliance failure on its own.
An enforcement procedure. Where to go if the response is unsatisfactory. Each member state designates this body; the statement has to name it.
Preparation details. The date the statement was prepared or last reviewed, and the method used: self-assessment or third-party evaluation.
Why a copied template is worse than nothing
A statement is a self-declaration, and the list of non-accessible content is the part that carries information. A template copied from another organisation, with the compliance status left at “fully compliant” and the barriers list empty, tells a reader two things: that the site has not been tested, and that the organisation is willing to declare things it has not checked.
That is a worse position than an empty page, because now there is a dated document with your name on it. Enforcement bodies in several member states have run sweeps comparing declared status against actual test results, and the gap is the finding.
A statement that is worth writing
The version that costs you least over time looks like this. Test the site, ideally with the manual checks in our testing walkthrough plus one round with real users of assistive technology. Write down what failed. Declare partial compliance. List the failures honestly, with a target date for each where you have one. Put a monitored address in the feedback section. Review it when you ship anything significant, and at least annually.
That document is defensible, it is useful to the people who read it, and it doubles as your own backlog.