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Is an accessibility statement required for an online shop?

For most web shops with a checkout process, the accessibility statement is a mandatory requirement under the law, but its content is just as important as its existence.

Is an accessibility statement required for an online shop?

For an online shop that falls under the European Accessibility Act, an accessibility statement is part of the obligations. The statement is not a checkbox you tick somewhere, but a public document that describes how far 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. Microenterprises that provide services and at the same time have fewer than ten employees and a turnover of no more than two million euros are outside the scope. For all other online shops with an online checkout step, the obligation generally applies. You can see which situation applies to you 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 block of text 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 is supposed to be a snapshot of reality, not a fixed template that was filled in once and never adjusted again. A statement that says the checkout step is accessible, but in the meantime a new payment screen has been added that was never tested, no longer describes what is actually on the site. When regulators review a statement, they look not only at its existence, but also at whether the content matches the current state of the online shop.

An underlying assessment must be in place

To complete a statement, an underlying assessment is needed: someone must have looked at which parts of the online shop were tested, using which method, and what came out of it. That justification does not need to be in the public statement itself, but should be recorded 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 keyboard only is correct. That a scan does not fully cover this should be stated in every report; it is not small print but a core point of what an automated test can and cannot do.

What an overlay widget does not solve

Some online shops choose an accessibility widget that claims to improve the site in 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 thereby does not describe the actual state of the site.

Review again after every 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 step, the login environment or other core components can make the previously made assessment outdated. Maintaining a statement is therefore less a one-time action than a recurring process, something that in practice is often underestimated alongside the initial effort to draw it up.

Which steps apply concretely to your situation, which market surveillance authority in your country is competent, and which declaration format is used there varies by Member State. An overview by topic, sorted by situation, is available in the knowledge base with explanations on each topic. What a full assessment, the report, and preparing the declaration itself cost is clearly shown in the subscription overview.

Would you first like to know whether this obligation applies to your webshop before reading further about the declaration's content? The free scope check and quick scan provide an initial indication within a few minutes, and the most frequently asked questions about the declaration itself are compiled in the answers to frequently asked questions.

This article is general information and not legal advice.