The European Accessibility Act (EAA) is no longer a "future" concern. With the June 28, 2025 deadline rapidly approaching, businesses selling digital products or services in the EU must ensure their platforms meet the EN 301 549 standards (the European equivalent of WCAG 2.1 Level AA).
One of the most visible requirements of this directive is the published Accessibility Statement.
This isn't a mere "we care about everyone" blurb in your footer. Under the EAA, an Accessibility Statement is a formal legal document that describes how your product conforms to standards, which parts fall short, and how users can report barriers.
In this guide, we’ll break down exactly how to write an EAA-compliant accessibility statement that protects your business and empowers your users.
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Why Your Current Statement Probably Isn't Enough
Most older accessibility statements are "aspirational." They use vague language like “We are working to improve our site.”
Under the EAA, that doesn't cut it. The directive mandates transparency. It requires you to be specific about what works and what doesn't. If a part of your checkout process isn't keyboard-friendly, you must declare it.
A compliant statement serves three purposes: 1. Legal Safety: It demonstrates a "good faith" effort to comply with EU law. 2. User Support: It gives people with disabilities a direct line to ask for help. 3. Accountability: It forces your product team to audit the site and know where the gaps are.
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The Mandatory Components of an EAA Statement
While the exact national laws (transposing the EAA) vary slightly between EU member states, the core requirements for an accessibility statement remain consistent. Your document should include:
1. Compliance Status You must clearly state if your website or app is: Fully compliant: All parts of the site meet the standards. Partially compliant: Most parts meet the standards, but there are specific exceptions. Non-compliant: The site does not yet meet the standard (this is a high-risk status).
2. Non-Accessible Content If you are partially compliant, you must list exactly what is not accessible and why. This is usually categorized into: Non-compliance with national law: Errors you intend to fix. Disproportionate burden: Features that are technically or financially impossible to fix right now (though this is hard to prove legally). Exempted content: Such as third-party maps or legacy archives.
3. Preparation Date You must state the date the statement was prepared and the last time it was reviewed. The EAA expects you to update this at least annually or after any major site overhaul.
4. Feedback Mechanism and Contact Information This is the most critical part. You must provide a way for users to report accessibility failures or request information that is currently trapped in an inaccessible format. Provide an email, a dedicated form, or a phone number.
5. Enforcement Procedure In the EU, if a user isn't happy with your response to their accessibility complaint, they have the right to contact an enforcement body. Your statement must point them toward the relevant national authority.
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How to Conduct the Necessary Audit
You cannot write an accurate statement without an audit. To fill out your eu-digital-product-accessibility-eaa-compliance-kit, you should perform a hybrid audit:
Automated Testing: Use tools like Axe or Lighthouse to catch low-hanging fruit (missing alt text, low contrast). Manual Testing: Have a specialist navigate your site using only a keyboard and screen readers (NVDA, JAWS, or VoiceOver). User Testing: Ideally, involve people with lived experience of disabilities to identify "logical" barriers that automated tools miss.
Once you have the audit results, you can fill in the "Non-accessible content" section of your statement with honesty.
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EAA-Compliant Accessibility Statement Template
Use the template below as a baseline. Replace the bracketed text with your specific company details.
> ### Accessibility Statement for [Product/Company Name] > > [Company Name] is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone and applying the relevant accessibility standards. > > #### Compliance Status > We firmly believe that the internet should be available and accessible to anyone. We strive to adhere as strictly as possible to the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines 2.1 (WCAG 2.1) at the AA level. > > [Product Name] is [partially/fully] compliant with the WCAG 2.1 Level AA standards due to the exemptions listed below. > > #### Non-Accessible Content > Despite our best efforts, there are some limitations. Below is a description of known limitations: > 1. [Feature Name]: [Describe the issue, e.g., "PDFs uploaded before 2023 are not fully screen-reader compatible."] We are working to [remediate/replace] these by [Date]. > 2. [Feature Name]: [Describe the issue, e.g., "The interactive map is not keyboard-navigable."] > > #### Preparation of this Statement > This statement was prepared on [Date]. It was last reviewed on [Date]. > The method used to prepare this statement was an actual assessment of the website/application by [Internal Audit/Third-Party Auditor Name]. > > #### Feedback and Contact Information > We welcome your feedback on the accessibility of [Product Name]. Please let us know if you encounter accessibility barriers: > Email: accessibility@[yourcompany].com > Phone: [Number] > Address: [Business Address] > > We aim to respond to accessibility feedback within [X] business days. > > #### Enforcement Procedure > If you are not satisfied with our response to your complaint, you may contact the [Name of National Regulatory Body in your EU Country].
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Best Practices for Implementation
Make it Easy to Find Don't bury your accessibility statement inside your Terms & Conditions. It should be a standalone page linked clearly from your footer. Label it "Accessibility" or "Accessibility Statement."
Use Plain Language Avoid overly technical jargon. The statement itself should be accessible. If a user with a cognitive disability is trying to find out how to use your site, the statement shouldn't be another barrier for them to climb.
Don't "Set and Forget" Digital products change weekly. Every new feature launch has the potential to break compliance. Update your statement every time a major update is pushed or at least once a year.
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Common Mistakes to Avoid
Using Accessibility Overlays: Many companies think a "one-line-of-code" overlay plugin makes them compliant. In many EU jurisdictions, overlays are criticized because they don't actually fix the underlying code and can interfere with a user's own assistive technology. Ignoring Third-Party Content: If your checkout uses a third-party widget that isn't accessible, you are still responsible for the barrier it creates for your customer. Vague Contact Info: Providing a general "info@" email address often leads to accessibility complaints getting lost in the noise. Use a dedicated channel.
Conclusion
Writing an EAA-compliant Accessibility Statement is more than a "check-the-box" exercise for legal. It’s a roadmap for your product’s inclusivity. By being transparent about where your product stands and providing a clear path for user feedback, you build trust and significantly reduce the risk of litigation as the 2025 deadline approaches.
If you haven't started your audit yet, now is the time to begin. Use our eu-digital-product-accessibility-eaa-compliance-kit framework to identify your gaps and draft a statement that reflects a genuine commitment to an accessible web.