Is an accessibility statement required for an online shop?

The declaration is mandatory, even if the website does not yet comply

Yes, an accessibility declaration is in principle mandatory for an online shop that falls within the scope of the European Accessibility Act — and this obligation is separate from the question of whether the website actually meets the standard. The declaration describes the current state: what is already accessible, what is not yet, and what plan exists to improve it. An online shop that is still actively working on improvements therefore simply publishes a declaration that states this, rather than waiting until everything is in order.

Micro-enterprises offering services are an exception to this: anyone with fewer than ten employees and a turnover of at most two million euros is outside the scope of the directive and therefore does not need to draw up a declaration. For those who do fall within it, the form of the declaration varies by country. In the Netherlands, the form is free as long as the content complies with the directive; in Germany, the document is called an Erklärung zur Barrierefreiheit and must be in German; in France a déclaration d'accessibilité in French; and in Belgium an accessibility declaration in Dutch or French, depending on the language region served by the online shop.

Where this follows from: the EAA and national laws

The obligation to provide an accessibility declaration follows from Directive (EU) 2019/882, which has been transposed into national legislation in each member state — in the Netherlands the Implementation Act on accessibility requirements for products and services, with the ACM as the supervisory authority for compliance. The ACM calls on companies to prepare for this and does not take into account whether a website is already fully accessible: the declaration and the associated improvement plan are precisely the instrument by which a company demonstrates that it is on the way, not proof that the process is already complete. In Germany, France and Belgium, the obligation runs through their own implementation of the same directive, with their own language and format for the declaration but the same underlying principle: the declaration should be there, even during the improvement process.