What is an accessibility statement?

In practice, the term causes real confusion, because EU accessibility law contains two separate documents, and the two are not interchangeable.

The EU declaration of conformity covers products: keyboards, cash machines, e-book readers, among others. It is governed by Article 16 and Annex IV of Directive (EU) 2019/882. The manufacturer assesses internally, on its own responsibility, that the product meets the requirements, affixes the CE marking, and keeps the declaration on file.

The accessibility statement, by contrast, covers services: an online shop, a banking app, a ticket-sales portal. It is governed by Article 13 and Annex V of the same directive. The provider does not get certified by any external body. Instead, it assesses on its own whether the service meets Annex I, and publishes that assessment publicly.

The name is not new in Spain. Since 2018, Royal Decree 1112/2018 has used it for public-sector websites and apps, together with an official template from the European Commission. Ley 11/2023, which transposes the 2019 directive for private companies, regulates the same obligation in its Article 13, but does not give it that exact name: the law speaks of information about compliance with the accessibility requirements. In practice, the industry keeps calling it an accessibility statement.

Annex V sets the minimum content. The statement must include a general description of the service in accessible formats, an explanation of how it works, and a review of how each requirement in Annex I is met: keyboard navigation, contrast, subtitles, compatibility with screen readers, among others. It must also state which parts are not yet met, and why.

Ley 11/2023 requires publishing it in the general terms and conditions or an equivalent document, in written and oral format, accessible to people with disabilities, and keeping it available for as long as the service stays in operation.

There is no dedicated official template for this statement under Ley 11/2023 or Directive (EU) 2019/882. An official template does exist, but it comes from a different, older act: Commission Implementing Decision (EU) 2018/1523, of 11 October 2018, designed for public-sector websites under Directive 2016/2102. Many private companies adapt it out of habit, not legal obligation.

The usual technical basis is the standard EN 301 549, which translates the legal requirements into verifiable WCAG criteria and serves as a common reference for assessing each point of Annex I. Its current version, 3.2.1, requires WCAG 2.1 level AA; a version 4.1.1 with WCAG 2.2 is planned for 2026, with no confirmed publication date as of this text.

The document is reviewed, when needed, by the market surveillance authorities that each administration designates for this purpose. In Spain, since 27 February 2026, there is also a Unidad técnica de apoyo y coordinación (technical support and coordination unit), created by Royal Decree 143/2026, which acts as a fallback authority wherever no other authority has been designated.

The accessibility statement is usually the first document a market surveillance authority asks for when it investigates a complaint. Article 13 requires the provider to keep it while the service is active, and to respond with evidence of conformity if the authority requests it. Without it, there is nothing to show.

In Spain, if there is no sanctions regime specific to the sector involved, Royal Legislative Decree 1/2013 applies on a supplementary basis: fines of up to 30,000 euros for a minor infringement, up to 90,000 euros for a serious one, per Article 20 of Ley 11/2023.

It also serves as evidence against a user who files a complaint. A dated text that states what works and what does not is harder to dispute in a complaint than silence or a generic sentence like "the website is accessible".

A public buyer evaluating suppliers before signing a contract also checks it: without it, the buyer cannot prove that its own procurement meets the accessibility requirements its own administration demands of it.

When a provider invokes the disproportionate burden exception under Article 14 of the directive to skip a requirement, it must document that assessment, keep it for five years, and hand it to the market surveillance authority on request.

There is a less obvious effect: publishing known gaps forces a company to keep a living list. A company that truly keeps it up to date tends to catch its own accessibility problems earlier, before a user or an authority finds them.

• Write one line per requirement in Annex I, not a generic paragraph: what is met, what is not, and since when.
• Publish a real contact channel for accessibility complaints, with a committed response time.
• Date every review, and repeat it at least once a year or after any relevant change to the service.
• If you start from the template in Decision 2018/1523, remove the sections written only for public bodies.
• Keep the previous version every time you update the statement, so you can prove what it said on a given date.
• Link the statement from the footer or the help menu; do not leave it sitting at an unlinked URL nobody can find.

• Confusing the accessibility statement with the EU declaration of conformity, and publishing the product's document instead of the service's.
• Copying the public-sector template (Decision 2018/1523) wholesale, including clauses about public bodies that do not apply to a private company.
• Writing that the service is fully accessible without having checked Annex I point by point.
• Leaving the statement without a date for its last review, which makes it useless as evidence.
• Not mentioning a single gap even though some exist: a statement with no acknowledged flaws is usually the first sign that the assessment was not done seriously.