The EAA accessibility statement — what it is and why most organisations don't have one
A published accessibility statement is a mandatory EAA requirement. Irish regulators request it first in any complaint investigation. Most organisations we speak with don't have one.
One of the four mandatory requirements of EAA compliance is a published accessibility statement. It is not optional, it is not a best practice, and it is not the same as a privacy policy or cookie notice. The absence of an accessibility statement is itself a compliance failure — before any audit has even been run.
What an accessibility statement is
An accessibility statement is a public declaration, published on your website or within your digital product, that sets out:
- Your current accessibility compliance position — what standard you are meeting and to what extent
- What is not yet fully accessible and why
- Your remediation plan — what you are doing to address the gaps and when
- How users can report accessibility issues or request accessible alternatives
- Contact details for accessibility queries
Why it matters beyond compliance
Irish regulators review the accessibility statement at the very start of any complaint process — before looking at anything else. It is typically the first document they request. An organisation without one starts any investigation at a disadvantage, regardless of how much technical work they have done on their product.
The statement also creates a documented baseline and an evidentiary trail — which is exactly what enforcement bodies look for when assessing whether an organisation was actively managing its obligations or simply ignoring them.
Most organisations we speak with don't have one. The accessibility statement is the most commonly missing EAA compliance requirement — and the easiest to address with structured support.
What makes a statement compliant
A compliant accessibility statement must be accurate, specific, and kept up to date. Generic statements that claim full WCAG 2.1 AA compliance without evidence, or that copy boilerplate from another organisation, are not compliant and can create additional legal exposure if the claims are inaccurate.
The statement must reflect your actual compliance position. If there are known barriers — and there almost always are — they must be documented along with a realistic timeline for remediation.
How frequently it needs updating
The accessibility statement should be reviewed and updated whenever significant changes are made to the product or service, and at least annually. If your compliance position improves, the statement should reflect that. If new issues are identified, they should be added.
Where the statement must be published
The statement must be easily findable. For websites, it should be accessible from the footer on every page, or at minimum from the main accessibility or legal information page. For apps, it should be accessible from within the app and from the app store listing.
Who needs an accessibility statement
Any organisation providing covered digital products or services to consumers in the EU. This includes organisations headquartered outside the EU — if you serve EU consumers, you are subject to EAA obligations including the accessibility statement requirement.
Microenterprises may be exempt from some EAA obligations, but should verify this specifically — the exemption does not apply uniformly across all obligations or all member states.
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