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European Accessibility Act (EAA) Accessibility Statement Guide: Template and Compliance for Website Owners

A practical guide for website owners on the European Accessibility Act (EAA) accessibility statement requirements. Includes step-by-step implementation, common mistakes, and how GDPRChecker scans help verify compliance.

Author

GDPRChecker Editorial Team

Reviewed by

Privacy & Compliance Research Team

Last updated

August 2026

Reading time

10 min read

Educational guidance for compliance readiness — not legal advice. Requirements vary by jurisdiction and your specific processing activities.

Introduction

*Updated for 2026 compliance practices.*

The European Accessibility Act (EAA) is reshaping digital compliance for website owners across the EU. While often discussed alongside GDPR, the EAA introduces distinct obligations—particularly around publishing an accessibility statement. This guide breaks down what the EAA accessibility statement means for your website, how to implement it step by step, and how to avoid common pitfalls. We’ll also show how GDPRChecker’s scanning tools can help you verify that your accessibility disclosures and consent mechanisms align with broader compliance expectations.

**Important:** This guide provides technical implementation guidance, not legal advice. Always consult a qualified professional for legal interpretations.

What is the European Accessibility Act (EAA) Accessibility Statement?

The European Accessibility Act (Directive 2019/882) aims to improve the accessibility of products and services in the EU internal market. For website owners, a key requirement is the **accessibility statement**—a public declaration that explains your site’s level of conformance with accessibility standards, typically WCAG 2.1. This statement must be easily findable, regularly updated, and include specific details such as:

  • The accessibility standard applied (e.g., EN 301 549, which references WCAG 2.1 Level AA).
  • Known accessibility barriers and alternatives.
  • Contact information for users to report issues or request accessible content.
  • The date the statement was last reviewed.

While the EAA primarily targets accessibility, it intersects with GDPR when accessibility features rely on user data (e.g., accessibility profiles that store preferences). Ensuring your accessibility statement is accurate and your consent mechanisms are transparent is where GDPRChecker’s scanning becomes valuable.

EAA Accessibility Statement vs. GDPR Compliance: Key Differences

Many website owners confuse EAA accessibility requirements with GDPR privacy obligations. The table below clarifies the distinctions:

| Aspect | EAA Accessibility Statement | GDPR Compliance | |--------|----------------------------|-----------------| | **Primary Focus** | Digital accessibility for users with disabilities | Protection of personal data and privacy | | **Key Requirement** | Public accessibility statement detailing conformance | Privacy policy, cookie consent, data subject rights | | **Standards** | WCAG 2.1, EN 301 549 | GDPR articles, ePrivacy Directive | | **Enforcement** | National market surveillance authorities | Data protection authorities (e.g., EDPB) | | **Overlap** | Accessibility features that process personal data (e.g., user preferences) | Consent for cookies/trackers that may impact accessibility tools |

Understanding these differences helps you allocate resources effectively. However, both require ongoing monitoring—something GDPRChecker’s scans can assist with.

Step-by-Step Implementation of an EAA Accessibility Statement

Implementing an accessibility statement involves more than just posting a page. Follow these steps to ensure compliance and verifiability:

1. Assess Your Current Accessibility Status Run an automated accessibility scan using tools like WAVE or Lighthouse, and supplement with manual testing. Document the WCAG 2.1 Level AA success criteria you meet and any failures.

2. Draft the Statement Using a Recognized Template Use the European Commission’s model accessibility statement or a national template. Note that EU member states may have additional requirements. For example, Germany’s BITV 2.0 mandates a specific structure and requires a detailed explanation of the evaluation method. France’s RGAA requires a compliance status and detailed audit results, including the percentage of criteria met. Italy’s Legge Stanca requires a clear accessibility statement with a feedback mechanism and a link to the national enforcement body. Spain’s UNE 139803:2012 standard requires a statement that includes the date of the last review and a list of non-accessible content. The Netherlands’ DigiToegankelijk standard requires a statement that follows the EU model but also includes a link to the national reporting mechanism. Check your target country’s rules. Include: - Name of the website/application. - Conformance status (e.g., “fully conformant,” “partially conformant”). - List of inaccessible content with planned remediation timelines. - Feedback mechanism (email, phone, contact form). - Enforcement procedure link (national body).

3. Integrate the Statement into Your Site Place the statement in a prominent location—typically the footer, linked as “Accessibility.” Ensure it’s accessible itself (e.g., proper heading structure, readable contrast).

4. Verify Consent and Tracking Interactions If your accessibility statement page loads any trackers (e.g., Google Analytics), ensure they respect user consent. GDPRChecker scans confirm that pre-consent network requests are blocked and that consent banners work correctly on this page.

5. Test with Real Users Engage users with disabilities to test your site and provide feedback on the statement’s usefulness. Update the statement based on their input.

6. Schedule Regular Reviews Set a recurring review cycle (e.g., every 6 months) to update the statement as your site changes. Use GDPRChecker’s monitoring to detect new trackers that might affect accessibility tool performance.

Common Mistakes and How to Avoid Them

Even well-intentioned website owners make errors that undermine EAA compliance. Here are the most frequent pitfalls:

  • **Publishing a boilerplate statement without verification:** A generic statement that claims full conformance without evidence can be misleading. Always back claims with audit results.
  • **Ignoring mobile accessibility:** The EAA applies to mobile apps and responsive websites. Test on various devices and screen readers.
  • **Overlooking third-party content:** Embedded widgets, social media feeds, or payment gateways must be accessible or have alternatives. Document any third-party barriers in your statement.
  • **Failing to link the statement from every page:** The statement should be reachable via a consistent link (e.g., footer) on all pages, including error pages.
  • **Not updating after site changes:** A redesign or new feature can introduce accessibility issues. Re-scan and update the statement promptly.
  • **Neglecting the feedback loop:** If users report barriers, respond and document actions. An unmonitored feedback channel can lead to complaints.

**Example:** A news website added a live chat widget that wasn’t keyboard-accessible. Their accessibility statement didn’t mention this, leading to user frustration. After a GDPRChecker scan revealed the widget’s pre-consent tracking, they reconfigured it to load only after consent and updated the statement to note the temporary barrier.

How to Validate Your EAA Accessibility Statement with GDPRChecker

GDPRChecker’s scanning platform is designed to verify compliance aspects that intersect with accessibility, particularly around consent and disclosures. Here’s how to use it for your accessibility statement:

  1. **Scan the statement page:** Run a public website scan on your accessibility statement URL. GDPRChecker will detect all cookies, trackers, and network requests.
  2. **Check pre-consent behavior:** Ensure no trackers fire before the user interacts with the consent banner. This is critical if your statement page includes analytics or accessibility preference cookies.
  3. **Verify banner functionality:** Test the “Reject” flow—does the banner correctly block all non-essential trackers? Confirm that accessibility-related cookies (if any) are categorized correctly.
  4. **Monitor for changes:** Set up recurring scans to catch new trackers or configuration drift that could affect both GDPR and EAA compliance.
  5. **Review policy links:** GDPRChecker checks that your privacy policy and cookie policy are linked and accessible, which complements the accessibility statement’s transparency goals.

For websites on paid plans, you can also manage consent banners, maintain a cookie inventory, and generate consent records—all of which support the documentation needed for EAA accountability.

Real-World Examples of EAA Accessibility Statement Implementation

Example 1: E-commerce Site An online store implemented an accessibility statement after an audit revealed keyboard navigation issues. They used GDPRChecker to ensure their consent banner didn’t block the accessibility widget’s essential cookies. The statement included a timeline for fixing the navigation and a contact email for assistance.

Example 2: Government Portal A public sector website published a detailed statement following the EU model template. They linked to their privacy policy and used GDPRChecker to verify that no third-party trackers loaded on the statement page without consent, maintaining trust.

Example 3: SaaS Dashboard A B2B SaaS company added an accessibility statement after integrating a screen-reader-friendly mode. GDPRChecker scans confirmed that the mode’s preference cookie was set only after explicit consent, aligning with both EAA and GDPR.

Implementation Checklist

Use this checklist to ensure your EAA accessibility statement is complete and verifiable:

  1. Conduct an accessibility audit (automated + manual) against WCAG 2.1 Level AA.
  2. Draft the statement using an official template (e.g., EU model statement).
  3. Include conformance status, known barriers, feedback contact, and last review date.
  4. Place a prominent “Accessibility” link in the site footer on all pages.
  5. Ensure the statement page itself is accessible (headings, contrast, keyboard navigation).
  6. Run a GDPRChecker scan on the statement page to detect trackers and pre-consent requests.
  7. Configure your consent banner to block non-essential trackers until user action.
  8. Test the “Reject” flow to confirm all optional trackers are suppressed.
  9. Document any third-party content barriers and alternatives.
  10. Set a recurring review schedule (e.g., every 6 months) and update the statement.
  11. Monitor for new trackers or site changes using GDPRChecker’s recurring scans.
  12. Respond to user feedback and log actions taken.

FAQ

What is the European Accessibility Act (EAA) accessibility statement? The EAA accessibility statement is a public declaration required for websites and mobile apps, detailing their conformance with accessibility standards like WCAG 2.1. It must include known barriers, contact information for feedback, and the date of last review. This statement helps users with disabilities understand how accessible your digital service is.

Do I need an EAA accessibility statement for GDPR compliance? No, the EAA accessibility statement is separate from GDPR. However, if your accessibility features process personal data (e.g., storing user preferences), you must also comply with GDPR. GDPRChecker scans can help ensure that any trackers on your accessibility statement page respect user consent.

How do I implement an EAA accessibility statement? Start with an accessibility audit, then draft the statement using an official template. Include conformance status, barriers, and contact details. Place the statement in your footer, ensure it’s accessible, and verify with GDPRChecker that no unauthorized trackers load on the page.

How can I verify my EAA accessibility statement with a scanner? Use GDPRChecker to scan your statement page for cookies and trackers. Check that pre-consent network requests are blocked and that the consent banner works correctly. Recurring scans help maintain compliance as your site evolves.

What are common EAA accessibility statement mistakes? Common mistakes include publishing a generic statement without audit evidence, ignoring mobile accessibility, overlooking third-party content barriers, not linking the statement from every page, and failing to update it after site changes. Regular reviews and scans can prevent these issues.

Which cookies and trackers should I check for EAA accessibility statement compliance? Check any trackers on your statement page, such as Google Analytics or accessibility preference cookies. Ensure they only load after user consent. GDPRChecker scans identify all such requests, helping you align with both EAA transparency and GDPR consent requirements.

How often should I review my EAA accessibility statement? Review your statement at least every 6 months or whenever you make significant site changes. Regular GDPRChecker scans can alert you to new trackers that might affect accessibility or privacy, prompting an update.

What evidence should I keep for EAA accessibility statement compliance? Maintain records of accessibility audits, user feedback, remediation actions, and scan reports. GDPRChecker’s consent records and scan histories can serve as evidence of your ongoing compliance efforts, demonstrating accountability to regulators.

Next Steps for Website Owners

Aligning with the European Accessibility Act doesn’t have to be overwhelming. Start by auditing your site, drafting a transparent accessibility statement, and integrating it visibly. Then, use GDPRChecker to scan your statement page and entire site for consent gaps, tracker misconfigurations, and disclosure issues. For deeper insights, explore our related guides:

  • Understand how [Google Analytics and GDPR compliance](/guides/google-analytics-gdpr-compliance) intersect with accessibility tracking.
  • Implement [Google Consent Mode v2](/guides/google-consent-mode-v2-guide) to manage tags responsibly.
  • Review the [basics of GDPR](/guides/what-is-gdpr) to ensure your privacy foundations are solid.
  • Check your [cookie policy requirements](/guides/cookie-policy-requirements) for full transparency.
  • Set up a [Google CMP](/guides/google-cmp-setup-guide) that respects user choices.
  • Dive into [GA4 cookie consent](/guides/ga4-cookie-consent-guide) for analytics-specific guidance.

**Ready to verify your site’s compliance?** Run a free GDPRChecker scan now to detect pre-consent requests, banner issues, and disclosure gaps—so you can close compliance gaps before they become problems.

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GDPRChecker guides are educational resources and do not constitute legal advice. Use them to understand technical and operational privacy requirements, and consult qualified counsel for legal interpretation.

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