What an accessibility statement for an online shop must contain

The European Accessibility Act (EAA) asks a provider of e-commerce services to consumers to make public information on how its service meets the accessibility requirements; microenterprises that provide services are exempt. The EU model accessibility statement is a template set up under a different directive, for public sector bodies.

Article 2(2) of the EAA covers e-commerce services provided to consumers after 28 June 2025. Article 3 defines e-commerce services as services provided at a distance, through websites and mobile device-based services, by electronic means, at the individual request of a consumer, with a view to concluding a consumer contract. Article 4(5) exempts microenterprises that provide services from the accessibility requirements and the obligations relating to them; the guide to the European Accessibility Act explains who counts as one.

Under Article 13(2), service providers “prepare the necessary information in accordance with Annex V” and “explain how the services meet the applicable accessibility requirements”. The W3C’s guide Developing an Accessibility Statement gives an example of when a statement is required: “In some situations, you may be required to provide an accessibility statement, such as public bodies in countries that implement the EU Web Accessibility Directive.”

Annex V of the EAA asks, where applicable, for three elements: a general description of the service, the explanations needed to understand how it operates, and a description of how it meets the accessibility requirements. The information goes in the general terms and conditions or an equivalent document.

Annex V states that the service provider includes the information “in the general terms and conditions, or equivalent document”. The information describes the applicable requirements and covers, as far as relevant for the assessment, the design and the operation of the service. Where applicable, it contains:

• (a) a general description of the service in accessible formats;
• (b) descriptions and explanations necessary for understanding the operation of the service;
• (c) a description of how the relevant accessibility requirements set out in Annex I are met by the service.

These elements come in addition to the consumer information that Directive 2011/83/EU requires. Article 13(2) adds the form and the duration: the information is made available to the public “in written and oral format, including in a manner which is accessible to persons with disabilities”, and kept “for as long as the service is in operation”.

In Germany, the BFSG asks for three elements that correspond to those of Annex V of the European Accessibility Act and adds a fourth: the competent market surveillance authority. For the BFSG, that authority is the MLBF in Magdeburg.

Under § 14(1) BFSG, a service provider may offer or provide its service only if the service meets the accessibility requirements of the regulation under § 3(2) BFSG (the BFSGV), and if the provider has prepared the information of Annex 3 (Anlage 3) and made it available to the public in accessible form. Annex 3 places the information in the general terms and conditions (Allgemeine Geschäftsbedingungen) or in another clearly perceptible way. It describes the applicable requirements, covers the design and the performance of the service as far as relevant, and contains:

• a) a general description of the service, in an accessible format;
• b) the descriptions and explanations needed to understand how the service is provided;
• c) a description of how the service meets the relevant accessibility requirements of the regulation under § 3(2) BFSG;
• d) the competent market surveillance authority.

The Bundesfachstelle Barrierefreiheit, Germany’s federal accessibility agency, says in its FAQ on electronic commerce that online shops fall under the BFSG in connection with services in electronic commerce, and that the providers of such services prepare this information and make it available to the public in accessible form. Its FAQ on services distinguishes the Annex 3 information from the Erklärung zur Barrierefreiheit, the accessibility statement of public bodies under the Behindertengleichstellungsgesetz (BGG). It gives a reference to harmonised standards or technical specifications as an example for element c). The FAQs are the agency’s reading of the law. More on the law is in the BFSG for online shops.

The authority for the BFSG is the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF). According to an announcement by the federal accessibility agency, the MLBF is based in Magdeburg, is responsible nationwide for market surveillance under the BFSG, and began its work when a state treaty took effect on 26 September 2025.

The EU model accessibility statement starts with a commitment and its scope, then has a section headed “Compliance status”, lists the content that is not accessible, says how the statement was prepared, and gives feedback and contact details and the enforcement procedure. Optional content may follow.

Commission Implementing Decision (EU) 2018/1523 of 11 October 2018 established the EU model accessibility statement under Article 7(2) of Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies, the Web Accessibility Directive. Article 7(1) of that directive has Member States ensure that public sector bodies provide and regularly update a “detailed, comprehensive and clear accessibility statement”, for websites in an accessible format, using the model. The model’s parts, in order:

1. Commitment and scope. The body commits to making its websites or apps accessible in accordance with the national law that transposes Directive (EU) 2016/2102, and names what the statement applies to.
2. Compliance status. One of the three options in the table below.
3. Non-accessible content. What is not accessible, grouped by reason: it does not meet the requirements, the body invokes a disproportionate burden, or it is outside the scope of the applicable legislation.
4. Preparation of this accessibility statement. The date, and the method: a self-assessment by the body, or an assessment by a third party, for which the model gives a certification as an example.
5. Feedback and contact information. A link to the feedback mechanism for reporting failures and asking for excluded content, and the contacts responsible.
6. Enforcement procedure. A link to the procedure for unsatisfactory responses, and the enforcement body’s contact information.

Optional content can follow “as deemed appropriate”.

The model says “compliant”. The W3C’s statement generator offers four conformance options instead: “Fully conformant”, “Partially conformant”, “Non conformant” and “Not assessed”.

The EU model was made for public sector bodies under the Web Accessibility Directive. For a shop, the EAA names the Annex V information and the BFSG names the Annex 3 information.

The model’s structure has places for a status, known barriers, contact details and an enforcement body. The general description of the service and the explanations needed to understand how it operates, which Annex V and Annex 3 both name, are not among its six parts listed above. Whether to follow the model’s structure, and in which document the information goes, is a decision for the shop and its legal counsel.

The EU model has a section for non-accessible content. For the BFSG, Germany’s federal accessibility agency says in its FAQ on services that non-conformity does not have to be stated and justified, because a service provider is in principle obliged to make its service fully accessible. The W3C advises listing known limitations.

The agency contrasts this with public bodies, which state which parts of a website or app are not yet fully accessible and why. “Does not have to” is not the same as “must not”. The W3C’s guide advises naming “any known limitations, to avoid frustration of your users”, and its generator has a field for “What to do in the meantime”. Whether a shop’s information lists known barriers is a decision for the shop and its legal counsel.

A useful statement is written for the people who use the shop, in plain language, and tells them whom to contact. That is the W3C’s advice, which is good practice rather than law.

The W3C’s guide Developing an Accessibility Statement says a statement should contain at least a commitment to accessibility for people with disabilities, the accessibility standard applied, such as WCAG 2.2, and contact information in case users encounter problems. It also advises known limitations, the measures taken, technical prerequisites such as supported web browsers, the environments in which the content was tested, and references to applicable laws and policies.

On language, the guide gives an example: rather than “WCAG Success Criterion 1.2.2 was not met”, it is better to say “videos do not have captions”. The W3C generator also has a field for the typical duration of a response to feedback.

Annex V of the EAA places the information in the general terms and conditions or an equivalent document. Annex 3 of the BFSG places it in the general terms and conditions or another clearly perceptible way; the federal accessibility agency names a website as an example.

For findability, the instructions in the Annex to Decision (EU) 2018/1523, written for public sector bodies, call for a link placed prominently on the home page or available on every page, for example in a static header or footer. The W3C advises linking the statement from several places, such as the footer, help menu, sitemap and about page, and using consistent link names.

For a shop, Article 13(2) of the EAA asks that the information be kept for as long as the service is in operation. For public sector bodies, the recitals of Decision (EU) 2018/1523 encourage a review of the statement at least once a year, and the model’s optional part recommends checking the accuracy of the statement’s claims at least once a year.

No. In both laws, publishing the information and meeting the accessibility requirements are separate. Article 13 of the EAA sets them in separate paragraphs: paragraph 1 has services designed and provided “in accordance with the accessibility requirements”, paragraph 2 asks for the information. § 14(1) BFSG names each as a condition for offering the service.

The W3C puts it this way: “Accessibility statements are not technical assessments or declarations of conformity, though they ideally refer to such background to provide verification and increase credibility.”

The Remediation Evidence Package includes a draft accessibility statement for the shop, marked “Draft for legal review”. Validiscan prepares it from the results of the package. It follows the structure of the EU model accessibility statement and adapts it to the European Accessibility Act for an online shop. Its notice says that the merchant’s legal counsel must review it before it is published, that Validiscan does not give legal advice, and that whether, where and in which languages the statement must be published depends on the law that applies to the merchant.

The draft’s sections:

• Commitment and scope, with the national law that transposes the EAA: the BFSG for a merchant in Germany, a field to complete for a merchant in another country.
• Status, in the model’s wording, with a sentence saying that it describes conformance with the Level AA success criteria of the WCAG versions it names, as evaluated on the pages and dates the statement names.
• Non-accessible content, in plain language per WCAG success criterion, marked “not met”, “partially met” or “fixed, verification pending”. For success criterion 1.2.2: “Some prerecorded videos have no captions, so people who cannot hear the sound miss the spoken content.”
• Preparation: the date, the package version, and the method, which the draft calls a self-assessment by the merchant, based on the evaluation in the package, and “not a certification”.
• Feedback and contact information, and the enforcement procedure with the market surveillance authority.
• Information about the service, the Annex V block: the service, using the service, the accessibility requirements and the accessibility features.
• A Before publishing checklist.

Text in square brackets marks what only the merchant can provide, such as the contact for accessibility feedback, the market surveillance authority for a merchant outside Germany, and a general description of the shop. The checklist asks for those fields to be completed, for a review by legal counsel, for publication in an accessible format, for example linked from the footer of every page, with a reference in the general terms and conditions, and for an update after every new evaluation. The application holds the draft’s text in English, German, Danish, French and Spanish.

The package itself says: “This package is evidence of an evaluation and of remediation work. It is not a certificate and does not state legal compliance.” The steps from the baseline scan to the package are described in how a project runs.