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Accessibility and the law

How to Write an Accessibility Statement That Is Actually True

18 August 2026 · 7 min read

Most accessibility statements on the web are one paragraph long and say approximately nothing: "We are committed to accessibility and strive to ensure our website is usable by everyone." It is well-intentioned, it costs nothing, and it is worth nothing to the person reading it.

A useful accessibility statement does three things a vague one cannot. It tells a disabled user, before they waste twenty minutes, whether the thing they need is likely to work. It gives them a route to tell you when it does not. And it demonstrates that your organisation knows the state of its own site — which is a far stronger position, legally and commercially, than a claim you cannot support.

In much of Europe it is also mandatory.

Where it is a legal requirement

EU public sector bodies must publish a detailed, comprehensive and clear accessibility statement under Article 7 of the Web Accessibility Directive. The model is set by a Commission Implementing Decision and prescribes the content: compliance status against the standard, the non-accessible content and why, a feedback mechanism, the enforcement procedure to escalate to, and the dates of preparation and last review.

UK public sector bodies have the same obligation under the 2018 accessibility regulations, and the government's guidance says statements should be reviewed at least every 12 months. The UK's monitoring programme has repeatedly found that statements are frequently out of date — which is its own kind of failure, because a statement claiming a fixed problem still exists, or an unfixed one is resolved, misleads the reader either way.

Under the European Accessibility Act, private-sector obligations differ by Member State, and the content required is not harmonised. France requires disclosure of inaccessible sections, accessible alternatives, a complaints route and an update date. Spain requires a complaint contact and an update date. Germany requires a service description, an explanation of compliance and the details of the market surveillance authority. If you sell into several EU countries, check each one — there is no single European template for private-sector statements.

Canada's new federal accessibility regulations, registered in December 2025, require published accessibility statements from the organisations they cover, updated annually.

Elsewhere — including for private businesses in the US and UK — a statement is voluntary. It is still worth having.

What a good statement contains

1. Which standard you are working to, and at what level. "WCAG 2.2 Level AA" is a sentence someone can verify. "Best practice accessibility standards" is not.

2. An honest compliance status. The EU model offers three positions: fully compliant, partially compliant, or not compliant. Almost every real website is partially compliant, and saying so is not an admission of failure — it is the normal state of a large site under active development. A statement claiming full conformance is a claim you must be able to defend across every page and every complete process.

3. What specifically is not accessible. This is the part organisations resist and the part users value most. Name the known problems: "Our PDF statements from before 2024 are not tagged and cannot be read reliably by screen readers." "The interactive map on the store finder cannot be operated by keyboard; store addresses are also listed as text below it." That second half — the alternative — is what turns a disclosure into help.

4. A feedback route that a human answers. A named email address or form, with a response time you actually meet. This is not decoration. Some legal complaints begin precisely because a user found a barrier and had no way to report it.

5. The escalation path, where one is required. EU and UK public sector statements must tell users where to go if your response is unsatisfactory — the enforcement procedure and the relevant body.

6. Dates. When the statement was prepared, when it was last reviewed, and ideally how the assessment was done — self-assessment, external audit, automated testing, user testing, or a combination. A statement with no date is an undated claim about a website that changes weekly.

7. What you are doing about it. A short, real roadmap with rough timelines. Not "we are committed to continuous improvement" — "the checkout is being rebuilt in Q4 2026, which will address the unlabelled fields listed above."

The overclaiming trap

Here is the risk that catches well-meaning organisations. An accessibility statement is a public representation about your product. If it is wrong, it is a wrong public representation about your product, and that has consequences beyond embarrassment.

There is no such thing as WCAG certification. The W3C does not certify anyone, and no body is authorised to. A logo or badge claiming certified compliance is either self-issued or issued by a commercial vendor with no standing to confer it.

Automated results do not equal conformance. A clean scan means the machine-detectable failures are gone — genuinely useful, and, on Deque's research, roughly a third of the WCAG 2.1 Level AA success criteria. It says nothing about whether alt text is meaningful, whether a screen reader user can complete checkout, or whether your custom components behave correctly. A statement reading "our site passes automated accessibility testing" is honest. "Our site is WCAG 2.2 AA compliant because it passes automated testing" is not.

Partial conformance is not conformance. WCAG has no percentage-based conformance, and in June 2026 a French court took exactly that position, holding a retailer's claimed 71% conformity insufficient when the obligation applied. Publishing "we are 94% conformant" as if it were a pass is a claim that has now been tested and failed in court.

Regulators do act on accessibility claims. In 2025 the US Federal Trade Commission ordered an accessibility widget vendor to pay $1 million, alleging its representations that its product made customer websites conformant were false, misleading or unsubstantiated. That was a vendor making claims about others' sites, but the principle is general: unsupported accessibility claims are consumer protection territory.

The safe formulation throughout is to describe what you tested, how, when, and what you found — rather than asserting a status. "Tested against WCAG 2.2 Level AA using automated scanning across all public pages and manual keyboard and screen reader testing of the purchase journey, most recently in July 2026" is specific, defensible and more useful to a reader than any badge.

A template you can adapt

Accessibility statement for [site] We want everyone to be able to use [site]. This statement explains how accessible it currently is, what we know is not working, and how to tell us about problems. How accessible this site is. We aim to meet WCAG 2.2 Level AA. This site is *partially conformant*: it meets most of the standard, with the known exceptions listed below. Known problems. [Specific list, each with a workaround where one exists and a rough fix date where you have one.] Telling us about a problem. Email [address] or use [form]. We aim to reply within [n] working days. If you need any content on this site in a different format, ask us and we will provide it. Enforcement. [Required for EU and UK public sector — name the enforcement body and route.] How we tested. [What was tested, by whom, using what methods, and when.] Prepared / last reviewed. [Dates.]

Keeping it true

A statement is a snapshot, and websites move. Three habits keep it honest: review it on a fixed schedule (annually at minimum, and it is a legal expectation for UK public sector bodies); update it whenever you ship a significant change to a journey it describes; and record what you actually tested each time, so the "how we tested" section stays accurate rather than aspirational.

If you have automated scanning running regularly, the raw material for those updates is already being produced — you are simply choosing to publish a truthful summary of it.

*Statement requirements are from Directive (EU) 2016/2102 and Commission Implementing Decision (EU) 2018/1523, the UK Public Sector Bodies Accessibility Regulations 2018 and GOV.UK guidance, published analyses of EAA national transpositions, and the Canadian regulations registered December 2025. The FTC matter is the accessiBe order, finalised April 2025. This is general information, not legal advice.*

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