An accessibility statement is not marketing copy. It is a declaration about a specific site at a specific date, and it is usually the first thing an enforcement body reads.
The instinct is to write as little as possible. That instinct is wrong: a statement that names known gaps and gives a date reads as a managed process, while a statement claiming full conformance is one counter-example away from being a false claim.
What has to be in it
EN 301 549 and the national rules built on it converge on the same components. The wording is yours; the components are not optional.
- —A conformance claim: fully, partially, or not conformant with WCAG 2.1 AA — and be precise, because "partially" is the honest answer for almost everyone.
- —The non-accessible content, listed, with why: not yet fixed, disproportionate burden, or outside scope.
- —How the assessment was done: self-assessment, third-party audit, automated testing, or a combination.
- —A feedback mechanism — an address that a human reads, and a response commitment.
- —An escalation route if the feedback goes nowhere.
- —The date it was prepared or last reviewed.
Why naming gaps is the safer choice
A claim of full conformance is falsifiable by a single unlabelled button. A statement that says "our archived PDFs published before 2024 are not accessible, and we will remediate on request within five working days" cannot be falsified — it is already true, and it gives the user a route.
Regulators are, in practice, far more interested in whether you have a process than in whether you are perfect today.
Keeping it current
A statement dated two years ago is evidence that nobody is looking. Review it whenever the conformance picture changes materially, and at least annually.
This is one of the reasons continuous scanning pays for itself: the score history is the audit trail behind the statement, and it updates itself.
A structure you can fill in
Six headings, in this order. Keep it on a stable URL, link it from the footer of every page, and make sure the statement page itself is accessible — it is the first thing anyone will check.
- —Commitment — one paragraph, plain language.
- —Conformance status — the claim, the standard, the version.
- —Known limitations — the honest list, each with a reason and, where you have one, a date.
- —How we test — tools, frequency, and any third-party audit.
- —Feedback — the address, and how quickly you reply.
- —Escalation — the national enforcement body, and the date of this statement.
Questions
- Does admitting to accessibility problems increase our legal risk?
- The opposite, in most jurisdictions. A documented, dated remediation plan is evidence of good faith. An unqualified conformance claim that turns out to be wrong is a misstatement.
- How often should the statement be reviewed?
- At least annually, and whenever a significant change to the site alters the conformance picture — a redesign, a new checkout, a migration.
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