
Accessibility statement: when required, what goes in it?
8 min read below · WebYes knowledge base
Last updated:
What changed: Checklist for a web shop statement added; difference from the duty to report explained; the yearly update duty for government now points to Digitoegankelijk.
Government or web shop: when to publish an accessibility statement, what the ACM requires (also orally) and how it differs from the duty to report.
An accessibility statement describes how accessible your website or app is, what does not work yet and how visitors get help. Government bodies publish it to the Digitoegankelijk model. Web shops under the EAA must offer it, easy to find, accessible and also orally, since 28 June 2025. A quality mark does not replace it.
What is an accessibility statement?
An accessibility statement is public status documentation: how accessible your website or app is, what still fails, and how you plan to improve it. According to Digitoegankelijk, your organisation accounts to supervisors and to visitors. The statement does not replace real accessibility; it describes the current state, including known gaps and a plan.
In practice a serious statement also needs evidence. For government that often means links to audit reports, a contact path for reports, and a plan for open issues. Without that context a statement is little more than an empty promise. With it, it becomes a working document you update after releases and re-audits.
The technical yardstick behind most requirements is WCAG level AA. The statement itself is not a quality-mark scorecard; it is a legal or regulatory compliance document. For the broader duty (government versus business), start with digital accessibility.
Government: mandatory under Digitoegankelijk
For government organisations the statement is legally required. Digitoegankelijk puts it bluntly: without a statement you do not meet the law, and you must create statements for all your websites and apps to a fixed model. Who is obliged? lists central government, provinces, municipalities, water boards and public-law bodies among others.
According to Digitoegankelijk, websites also include intranets, extranets and cloud applications; apps include native, web and hybrid apps. Every government website or app gets a status from A to E. Status A, B or C meets the law; status E means there is still no statement. Status A or B requires a full accessibility audit as evidence.
After you publish, Digitoegankelijk reviews the statement and suggests improvements. According to Digitoegankelijk every statement must be updated at least once a year, and an audit is valid for 3 years. A statement that sits unchanged drops in status. Publishing is step one; keeping it current is the real work.
E-commerce services: a statement duty too
Since 28 June 2025 the European Accessibility Act (EAA) applies to e-commerce services among others. According to ACM guidance, the accessibility duty covers providers with 10 or more employees or annual turnover above 2 million euros. Micro-enterprises below both thresholds are exempt.
Services in scope also have a statement duty: you explain how your service meets the accessibility rules, in a place that is easy to find. Think footer, help centre or account menu. The ACM line we use on this site matches our EAA page: be accessible and document it; a quality mark is not legally required.
The government model and Digitoegankelijk dashboard are not the standard route for a web shop. The underlying idea is the same: be honest about what works, what still fails, and how visitors can give feedback. A checkout that only works with a mouse belongs in that documentation until you fix it.
What goes in the EAA statement of a web shop? The ACM does not prescribe a fixed model as for government, but it does say what the statement must do. Use this checklist:
| Checklist item |
|---|
| Explain how your service works and how it works with assistive technology such as a screen reader or keyboard. |
| Describe in what way you meet the accessibility rules. We recommend also stating which parts do not comply yet. |
| Make the statement easy to find (for example in the footer) and itself accessible. |
| Offer the statement orally too, for example as an audio clip in which the text is read aloud. |
| Make sure your customer service can answer questions about accessibility, through channels that are themselves accessible. |
| Do you sell products or services from others? Also give information about their accessibility; your supplier or manufacturer has to provide it. |
| According to the ACM, staying accessible is not a one-off action: with every change you make sure the service stays accessible. We recommend updating the statement after larger changes. |
Want to back up your statement? Use the scan as evidence for your statement, then walk through the buying process with our EAA checklist for web shops. WebYes also publishes its own statement.
Statement and duty to report: two different things
The statement is public and aimed at your visitors. The duty to report is a notification to the ACM: if you cannot fix an accessibility problem right away, you report it within 1 week (critical or serious) or 1 month (moderate or minor), with a plan of action. An honest statement does not replace that report. More on deadlines and exceptions on our page on the European Accessibility Act.
Assistant for the government model
Government bodies create the statement via the assistant at toegankelijkheidsverklaring.nl. Digitoegankelijk describes that wizard as the way to produce statements that meet the mandatory model. You need an account at toegankelijkheidsverklaring.nl.
Before you start, according to Digitoegankelijk, you gather among other things: web addresses or app-store links, links to audit reports, which success criteria still have problems, a date by which the problems are fixed at the latest with the measures and alternatives until then, links to contact and complaints procedure, and the name and role of the director or manager who signs. Without those pieces you stall in a draft.
After publication the statement enters the register. Digitoegankelijk notes that the accessibility label (or the full HTML statement) must go on the site; a bare link alone is not enough for government. Companies under the EAA usually do not use this government portal as their legal channel, but can still use the structure as a checklist: scope, evidence, feedback path, plan.
The WebYes mark is not a legal statement
WebYes is an independent website review on four pillars: accessibility, speed, security and mobile. GEKEURD means that at audit time your site met our thresholds: average at least 80, and at least 60 per pillar. That is not a Digitoegankelijk status A to E, and not an ACM statement under the EAA.
Our scan runs automated checks against WCAG 2.2 AA and covers up to six pages per run. That helps find quick, measurable problems: missing alt texts, low contrast, empty buttons, missing form labels. Automated checks do not catch everything; government status A or B still needs a full audit, and EAA certainty on checkout often needs manual testing.
Use WebYes as a starting point for remediation, not as a substitute for the legal statement. Measure where you stand first, fix the blockers, then publish an honest statement through the right channel (government: Digitoegankelijk model; e-commerce: a findable status page along ACM guidance).
Checklist before you sign off
Check that the scope is right: which URLs and apps fall under this statement, and which do not. Note the research date and whether it was an automated sample (WebYes: free up to six pages, full audit up to fifteen) or a full manual investigation. Without that nuance the text reads as if everything is AA while only lab checks were done.
Put open fails with owner and deadline in the remediation plan. Wire feedback channels (contact, complaint) that are actually staffed. Only then sign: a statement without a fix path is paper, not compliance. Repeat after releases and after re-audit so status A/B or EAA claims do not go stale.
Sources
- Toegankelijkheid e-handelsdiensten - ACM (consulted on 13 October 2026)
- De toegankelijkheidsverklaring - Digitoegankelijk (consulted on 13 October 2026)
- Invulassistent Toegankelijkheidsverklaring (consulted on 13 October 2026)
- Voor wie is het verplicht? - Digitoegankelijk (consulted on 13 October 2026)
Frequently asked questions
Does every website need an accessibility statement?
No. Government organisations must publish one for their websites and apps. E-commerce services under the EAA also have a statement duty per ACM guidance, for businesses with 10 or more employees or over 2 million euros in annual turnover. A small informational site outside those scopes has no legal statement duty.
Where do government organisations create the statement?
Via the assistant at toegankelijkheidsverklaring.nl. Digitoegankelijk requires statements to the fixed model; the assistant produces that model. After publication you place the accessibility label or the HTML statement on your site.
Does the WebYes quality mark replace my accessibility statement?
No. The mark shows that at scan time you met our thresholds (average ≥80, per pillar ≥60, max six pages, automated WCAG 2.2 AA). The legal statement is separate compliance documentation. You need both if you fall under the government duty or the EAA statement duty and also want to show a quality mark.
What do I put in a statement if not everything is AA yet?
Be honest: state what already complies, which gaps are known, which temporary measures or alternatives you offer, and when you expect fixes. Digitoegankelijk asks that explicitly for government; for e-commerce the same honesty is the only useful form. A statement that claims perfection while checkout fails helps no one. Also note whether the sample was automated (for example WebYes up to six or fifteen pages) or manual.
Does my statement also have to be available as audio?
According to the ACM you must also offer the statement orally, for example with an audio clip in which the text is read aloud.
Is a statement the same as a report to the ACM?
No. The statement is for visitors; you report to the ACM when you do not fix a problem right away.
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