Er en tilgængelighedserklæring obligatorisk for en webshop?
For an online shop that falls under the European Accessibility Directive, an accessibility statement is part of the obligations. The statement is not a checkbox you tick somewhere, but a public document that describes how your online shop complies with the EN 301 549 standard, which parts do not yet comply, and how visitors can report a problem.
Whether the obligation applies to your online shop depends on the scope of the directive. Micro-enterprises that provide services and have fewer than ten employees and a turnover of at most two million euros are outside the scope. For all other online shops with an online checkout process, the obligation generally applies. Which situation applies to you can be determined in a few minutes with the free scope check that assesses your situation.
What exactly must be included
An accessibility statement is more than a text block at the bottom of the page. The statement typically describes which parts of the online shop the standard applies to, which parts comply and which do not, and on what basis that assessment was made. In addition, there must be a way for visitors to report an accessibility problem and what happens when such a report is received.
The detail where things often go wrong in practice is that the statement should be a snapshot of reality, not a fixed template that was filled in once and never adjusted again. A statement that says the checkout is accessible, but in the meantime a new payment screen has been added that was never tested, does not describe what is actually on the site. Supervisory authorities do not only check whether a statement exists, but also whether its content matches the current state of the online shop.
The self-assessment must be there
To complete a statement, an underlying assessment is needed: someone must have looked at which parts of the online shop were tested, with which method, and what came out of it. This justification does not need to be in the public statement itself, but should be documented somewhere so you can show what the statement is based on. A statement without any form of assessment behind it is essentially a blank claim.
This is also why an automated scan alone, useful as it is, does not tell the whole story. An automated test recognizes some WCAG criteria well, such as missing alternative text or insufficient color contrast, but cannot assess whether a form feels logical with a screen reader or whether the operation sequence with a keyboard only works correctly. That a scan does not fully cover this should be stated in every report; it is not small print but a key point of what an automated test can and cannot do.
What an overlay widget does not solve
Some online shops opt for an accessibility widget that claims to improve the site with a few clicks. Such an overlay sometimes adjusts the font or contrast, but does not replace the underlying code structure and therefore does not solve what a screen reader user or keyboard user actually encounters. An accessibility statement that only refers to such a widget as evidence of compliance does not thereby describe the actual state of the site.
Check again after each change
An online shop rarely stands still: a new checkout provider, a different theme, an extra step in the ordering process. Any change to the checkout, login environment or other key components can make the previously completed assessment outdated. Maintaining a statement is therefore less of a one-time action than a recurring process, something that is often underestimated in practice alongside the initial effort to draw it up.
Hvilke trin der konkret gælder for din situation, hvilken marktilsynsmyndighed i dit land, der er kompetent, og hvilket erklæringsformat, der bruges der, varierer fra medlemsstat til medlemsstat. Et overblik pr. emne, udarbejdet pr. situation, findes i vidensbasen med forklaringer pr. emne. Hvad en fuldstændig vurdering, rapporten og udarbejdelsen af selve erklæringen koster, fremgår tydeligt under oversigten over abonnementer.
Vil du først vide, om denne forpligtelse gælder for din webshop, før du læser videre om indholdet af erklæringen? Det gratis scope-check og quick-scan giver inden for få minutter en første indikation, og de mest stillede spørgsmål om selve erklæringen er samlet under svarene på ofte stillede spørgsmål.