Skip to content

The Accessibility Statement Nobody Reads Until Late

The European Accessibility Act has been in force since June 2025, and the first thing an enforcement body or a claimant's lawyer looks for is your accessibility statement — the page that documents how accessible your website, app or service actually is. Most businesses don't have one. Some have one from 2023 that no longer matches the site.

This is the deep-dive on the last of the five legal pages from the overview post.

What the statement actually is

An accessibility statement is the documented declaration of conformance with WCAG — the Web Content Accessibility Guidelines — including which level you meet (the common target is WCAG 2.1 AA), which parts of the site are covered, known issues, and who to contact about accessibility problems.

The format matters less than the honesty. A statement that claims full conformance while the site has obvious barriers is worse than no statement — it converts a compliance gap into a misrepresentation. The WCAG guide we published covers the technical side in the WCAG compliance guide, and there's a how-to on writing and publishing one.

Who has to care

Two forces, one from each side of the Atlantic:

  • Europe: the European Accessibility Act applies to products and services sold to EU consumers — e-commerce sites, apps, banking services, transport ticketing — with national enforcement and penalties. The statement is part of the documentation trail the act expects.
  • United States: ADA website lawsuits have run in the thousands per year for a decade, and the demand letter almost always cites the absence or inadequacy of an accessibility statement as evidence of indifference. A dated, honest statement is not immunity, but it is the first thing that changes a negotiation.

What happens without one

An enforcement complaint or a lawsuit doesn't start with an audit of your code. It starts with a claimant who couldn't use your site, and the first documents requested are your accessibility policy and statement. Not having them puts you in the position of arguing you care about accessibility while producing no evidence of it.

There's a quieter cost too: procurement. Enterprise buyers and public-sector contracts increasingly ask for the statement as part of vendor checks, same as a DPA or an ISO certificate. Missing it means answering a questionnaire instead of pasting a link.

Why the page must stay current

Accessibility is never finished — the site changes, the app ships features, WCAG guidance evolves. A statement that isn't dated and maintained drifts from reality within a quarter, and the drift is discoverable. The SaaS trust-center pattern applies cleanly here: one living page, dated and versioned, updated when the site changes, sitting in the same trust section as your other legal documents. We host our own accessibility statement exactly that way on our public Trust Hex — the same page we point regulators and buyers to.

How Sustalium Helps with Accessibility

  • A living, dated statement — permanent URL, updated in place when the site or app changes.
  • Part of your Trust Hex — the statement sits beside your other legal pages at one verifiable address.
  • One link for every ask — regulators, buyers and claimants all check the same current version.

Document Accessibility or Explain Its Absence

Publish an honest, dated statement and keep it current with your site. See the platform with your own data, free demo: no card required.

See Our Accessibility Page, Hosted the Same Way →

Frequently Asked Questions

Does the European Accessibility Act apply to my small business?

It applies by product and service category, not size — e-commerce, apps, banking, transport and similar consumer-facing services are in scope across the EU. Check your category before assuming exemption.

What level should I target?

WCAG 2.1 AA is the practical standard that satisfies both the EAA and most US settlements. AAA is aspirational; A is insufficient.

How honest should the statement be?

Completely. List the known issues and the contact for reporting more. An honest partial statement beats a false full one in every enforcement scenario.

Last updated: October 1, 2026

Global Digital Trust & Compliance

Sustalium is the digital-first platform for managing complex business certificates and sustainability declarations across global supply chains.

Environment & ESG
  • Digital Product Passport (DPP)
  • Carbon & Water Footprint
  • Circularity & Reuse (ISO 14021)
  • De-Forestation Free
Product & Food Safety
  • FSMA 204 (FDA Traceability)
  • REACH & RoHS Compliance
  • PFAS-Free & VOC Declarations
  • Prop 65 & TSCA Title VI
Social & Ethical
  • ISO 26000 Responsibility
  • Modern Slavery Statements
  • UFLPA Forced Labor Traceability
  • Ethical Labor Declarations
Governance & Trade
  • Swiss Made & Origin Claims
  • GDPR & AI Ethics (EU AI Act)
  • CE Marking & UKCA Conformity
  • Bill S-211 (Canada) Reporting
Start Free

Have questions about a specific standard?
Contact our compliance team at compliance@sustalium.com