The European Accessibility Act (EAA) (EU Directive 2019/882) is a law in the European Union that sets common rules for making products and services accessible to everyone, including people with disabilities. Its goal is to make sure that things like websites, mobile apps, online shopping, banking, and transportation services are easy for everyone to use, regardless of their abilities.
This guide will walk you through the key steps to creating an Accessibility Statement that aligns with the requirements of the EAA. We’ll break down the legal obligations, provide practical advice, and offer clear examples of how to meet these requirements.
One important part of the law, Article 13(2), requires businesses and service providers to explain how they make their services accessible. This information needs to be shared publicly and in a way that everyone, including people with disabilities, can understand. This is typically done through an Accessibility Statement, which follows the rules in Annex V of the EAA.
Service providers must create and share information about how their services meet accessibility requirements. This information must be available both in writing and verbally, and it should be easy for people with disabilities to access. The information should also stay available for as long as the service is running.
The purpose of this provision is to ensure that service providers are transparent about the accessibility of their services, outline the specific accessibility requirements that must be met, and provide clear information to users and regulators about how accessibility is being addressed.
Legal Requirement (Annex V, 1(a)):
a general description of the service in accessible formats;
Directive Requirements:
The law requires that service providers give a plain, clear description of what their service is about and make sure that description is available in accessible formats. This means that everyone, including people with disabilities, should be able to understand what the service is and how it works. For example, a visually impaired person should be able to access this description through a screen reader.
Practical Meaning for Organizations:
You should prepare a simple, concise description of your service, written in clear language. This description should be available in a format accessible to people with different needs, such as text that works well with screen readers or alternatives like audio or large print on request. This section is similar to an “About” section on your website, explaining what your service does and who it is for.
Compliance Guidance:
Create a section in your accessibility statement titled “Service Overview.” In this section, describe what your service is and what it offers in clear and simple language. Make sure the description is available in formats like audio or braille on request.
Keep copies of your service description in different accessible formats. For example have:
Additionally, you might want to test the description with a screen reader to ensure it is fully accessible. Keep records of any requests for alternate formats and how you fulfilled them. These steps show that you not only wrote the description but also ensured it is available in accessible ways, as required by the law.
Legal Requirement (Annex V, 1(b)):
“descriptions and explanations necessary for the understanding of the operation of the service;”
Directive Requirements:
The service must provide instructions on how to use it, especially for people with disabilities. This could include explaining how to navigate your website or app, how to use accessibility features, or how to complete tasks like making a purchase. The goal is to make sure users know how to operate the service in an accessible way.
Practical Meaning for Organizations:
Include a simple guide in your accessibility statement explaining how to use your service. This might include instructions on how to navigate the site, use accessibility features like captions or text resizing, and complete tasks like creating an account or making a purchase.
Compliance Guidance:
Create a section titled “How to Use the Service” and describe how to navigate the service and use any special accessibility features, including a description of what deviates from common navigation behavior. For example, “The service provides detailed instructions on how to use it. You can access the full guide at this link…”, “You can use the ‘Tab’ key to navigate our website and press ‘Enter’ to activate links.” or “The service is designed to work with standard browser and assistive technology commands, except…”. Keep the explanations simple and make sure they are in an accessible format.
Legal Requirement (Annex V, 1(c)):
“a description of how the relevant accessibility requirements set out in Annex I are met by the service.”
Directive Requirements:
You need to explain how your service meets the accessibility requirements listed in Annex I (Section III and IV) of the EAA (functional requirements and technical outcomes that the service should achieve, such as perceivability, operability, compatibility with assistive tech, etc.). This is a way to demonstrate that your service is accessible and follows the law’s standards. It’s essentially a compliance statement or self-assessment summary: rather than just saying “we comply,” the provider should give an informative account of the measures taken to fulfill each relevant requirement. This transparency is intended both for users (to know the service’s accessibility features/levels) and for regulators who might review the statement to verify compliance claims.
Practical Meaning for Organizations:
In your accessibility statement, describe how your service meets the EAA’s accessibility criteria. This could include explaining how you follow standards like WCAG 2.x AA (latest) for web content or EN 301 549 for ICT services.
Compliance Guidance:
Structure this part as an “Accessibility Compliance” or “How We Meet Requirements” section. One practical way is to group by category of requirements or by standard. For example, you could write a short paragraph for each of the WCAG/EN 301 549 principles:
If you follow a recognized standard, you can simply state your conformity to it. For example, you might say, “We comply with WCAG 2.x AA (latest) at Level AA for our web content,” which covers many Annex I requirements. Be accurate: if your service fully meets all requirements, this is a claim of full compliance, so be prepared to back it up with evidence. If only some requirements are met or if some issues are still being addressed, be transparent about it here. You may also need to mention limitations or derogations in a later section (e.g., disproportionate burden).
Keep this section user-friendly, even if it’s about technical compliance. Avoid listing raw WCAG criteria codes and instead describe features in simple terms, such as, “All images have alt text,” “All functions are keyboard-accessible,” or “Our text meets recommended contrast ratios.” Strive for a balance: detailed enough to cover requirements, but clear enough for non-experts to understand.
To support this section, keep an accessibility evaluation report or checklist on hand. This could include a WCAG audit, an internal conformance assessment, or a third-party certification. For example, maintain a copy of a WCAG 2.x AA (latest) audit report or an EN 301 549 compliance report for your website/app, with evidence for each requirement (like code snippets or screenshots).
Also, keep records of any issues found and fixed, such as bug trackers or project plans showing how you addressed non-compliance points. If a requirement is not applicable (NA) or exempt due to disproportionate burden, document the rationale. The Directive expects service providers to have this technical documentation available for market surveillance authorities.
Finally, retain a copy of the Annex I checklist you used (e.g., an annotated Annex I or WCAG summary) to show you systematically reviewed all points.
Legal Provision (Annex V, Point 2):
“To comply with point 1 of this Annex the service provider may apply in full or in part the harmonised standards and technical specifications, for which references have been published in the Official Journal of the European Union.”
Directive Requirements:
This clause is not a content to include in the statement per se, but a method of compliance. It states that a service provider may rely on harmonised standards (in whole or part) to meet the obligations in point 1 (i.e. the requirements we listed above for content of the statement).
In EU law, using a harmonised standard whose reference is published in the Official Journal gives a “presumption of conformity”. The key standard for digital accessibility is EN 301 549, which aligns with WCAG for web/mobile content and includes other ICT accessibility criteria. By following such standards, a provider can more easily demonstrate that they meet the EAA requirements.
Practical Meaning for Organizations:
In your statement’s compliance section, you might explicitly say “This website conforms to EN 301 549 and WCAG 2.x AA (latest).” This gives readers and regulators a clear benchmark. Using the standard doesn’t replace the need to provide the info in Annex V (you still need the descriptions, etc.), but it can be referenced as a shorthand for compliance level. Essentially, it’s telling you how to comply: by following harmonised standards you both actually make your service accessible and you have a ready-made way to describe your compliance.
Compliance Guidance:
In your statement, mention any standards followed in the “Conformance status” or Introduction. For example, you could say, “We aim to comply with WCAG 2.x AA (latest)” or “This service follows EN 301 549 v3.2.1 (the European ICT accessibility standard).” Be honest about your conformance, if only part of a standard applies, say so (e.g., “We have applied standard X in part”). The relevant harmonised standards for EAA services include EN 301 549 (for ICT services like websites and apps) and EN 17161 (which is more for organizational processes). Referencing these not only adds credibility to your statement but also invokes the “presumption of conformity,” where regulators assume compliance if the standard is met. In short, clearly state the standards you’re using as the basis for accessibility.
Legal Requirement (Annex V, Point 3):
“The service provider shall provide information demonstrating that the service delivery process and its monitoring ensure compliance of the service with point 1 of this Annex and with the applicable requirements of this Directive.”
Legal Interpretation & Purpose:
This requirement ensures that accessibility is not just a one-time effort but is maintained throughout the service’s lifecycle. You must show that you have processes in place to keep accessibility up to date as your service evolves.
Practical Meaning for Organizations:
You need to have a clear workflow for maintaining accessibility, including policies, roles, and daily activities. This could involve staff training, integrating accessibility checks into development, using tools to scan for issues, responding to user feedback, and conducting regular reviews or audits. Essentially, document your accessibility program. For example, you might have an accessibility officer or team, a schedule for re-testing the site, and processes for monitoring user reports. The EAA expects providers to adapt to changes, such as new standards or features, to maintain compliance. Make sure your statement reflects that accessibility is actively managed, showing that compliance is ongoing, not static.
Compliance Guidance:
Include a section in your accessibility statement, such as “Maintenance and Monitoring of Accessibility,” where you outline how your organization ensures ongoing accessibility. Be specific about processes, like developer training or regular use of auditing tools.
For example, mention steps like, “We conduct quarterly accessibility audits,” “We have an accessibility champion on the product team,” or “All new content is checked for accessibility.” Include any feedback mechanisms, like “We monitor and respond to accessibility issues reported by users.”
You might also note that accessibility is reviewed at the executive level or that the company follows an official policy aligning with accessibility standards (such as EN 17161, which is about integrating accessibility into organizational processes). This section should show that accessibility is a continuous priority, reassuring users and demonstrating compliance with the requirement for ongoing conformity.
To evidence your ongoing accessibility efforts, maintain documentation of your accessibility policies and procedures. This could include:
If you use monitoring tools or have a service agreement with an accessibility consultant, keep those records as well. EN 17161 certification or alignment can also serve as evidence, as it’s about integrating accessibility into organizational processes. Additionally, keep contact logs for user feedback—documenting issues and responses shows you’re actively monitoring and responding.
All these documents demonstrate proactive accessibility management, ensuring compliance with Annex V(3). Essentially, you should be able to show an inspector how you maintain compliance, with clear procedures and evidence that they are being followed.
Why Include This Section?
While not explicitly required by Annex V, disclosing known limitations aligns with best practices outlined in the Web Accessibility Directive (EU Directive 2016/2102) and reflects a proactive approach to compliance management.
If there are limitations, disclose any parts of the service that are not fully accessible, with reasons and alternatives.
Legal Requirement (Article 14):
The accessibility requirements referred to in Article 4 shall apply only to the extent that compliance: (a) does not require a significant change in a product or service that results in the fundamental alteration of its basic nature; and (b) does not result in the imposition of a disproportionate burden on the economic operators concerned.
Why Include This?
This section should be included only if you are claiming a specific exception under Article 14 of the EAA for any requirement that is not met due to a disproportionate burden. If applicable, state which requirement cannot be met, why (costs, etc.), and any timelines to review that decision.
Note: since some requirements can be fulfilled at minimal cost, the disproportionate burden cannot be applied to the service as a whole, but only to specific elements. You may also consider completing this section if, for example, a complete redesign of the service is planned, or in similar circumstances where implementing certain requirements may not be feasible at the current stage.
Why Include Feedback?
Although not explicitly listed in Annex V, providing a way for users to report accessibility issues is good practice. It shows you are open to feedback and willing to improve. Include clear contact information, like an email address and phone number, and make it easy for users to reach out if they have problems.
Compliance Guidance:
We recommend adding a “Feedback and Contact Information” section, providing multiple contact methods for users to report accessibility issues.
Also, if applicable, inform users of their rights to escalate complaints to an authority if they are not satisfied with your response. For example, you might mention that in [Country], the regulatory authority is XYZ, with a link, per national implementation. Even if not strictly mandated by Annex V, this is in line with best practices and demonstrates good faith compliance and customer care.
Ensure your customer support or accessibility team has a clear process for handling feedback, such as a ticket system specifically tagged for “accessibility issues.” Keep records of all feedback and how it was addressed. If you provide an email for feedback, ensure that mailbox is regularly monitored. Similarly, if you list a phone number, make sure staff are trained to handle accessibility-related calls and have scripts or knowledge resources to log issues or provide assistance.
In your statement, always include the date of the last update—maintaining version history helps demonstrate that the information is regularly reviewed. It’s also smart to have an internal escalation process in case a user files a complaint with authorities. Document how you’ll cooperate with any official enforcement inquiry, as required by Article 13(3) and 13(5).
Italy has implemented the EAA through Legislative Decree No. 82 of 27 May 2022 (D.Lgs. 82/2022). This decree follows the core requirements of the EAA, so the main content of an accessibility statement, as described earlier, is applicable. However, there are some specific considerations for Italy that need to be taken into account to fully align with national regulations:
For Italy, the accessibility statement must be in Italian and written in clear and simple language. The template can be translated to meet this requirement. Additionally, any alternate formats (such as oral or braille versions) must also be provided in Italian. This ensures the statement is accessible to persons with disabilities in the local language.
Although not legally required, it is helpful to mention that the statement is made in accordance with Directive (EU) 2019/882 as implemented by D.Lgs. 82/2022. This clarification can be added in your statement, for example:
“La presente dichiarazione di accessibilità è redatta ai sensi del D.Lgs. 82/2022 (Attuazione della Direttiva UE 2019/882).”
Including this will make it clear that the statement is fulfilling Italy’s national EAA obligations.
Italy’s regulations designate multiple authorities responsible for enforcing accessibility in different sectors. Some of the key bodies include:
Currently, there isn’t a single portal for submitting EAA complaints in Italy. Until further clarification, it is sufficient to include a generic line such as:
“In Italia, l’ente di controllo dell’accessibilità dipende dal settore del servizio; vi assisteremo nel contattare l’autorità competente qualora necessario.”
Alternatively, you may choose to provide contact information for AgID in your statement for general queries related to accessibility compliance.
However, in the near future, AgID will provide a platform that enables users to submit complaints and stay informed about related activities and subsequent decisions. In addition, the same platform will allow service providers to report non-compliance issues.
Some Italian companies might already be familiar with Legge Stanca (Law 4/2004), which mandates public sector websites, as well as private companies with a three-year average turnover exceeding €500 million, to have an accessibility statement and feedback mechanism.
If a company is subject to both Legge Stanca and the EAA, the statement should comply with both sets of requirements. Fortunately, the requirements overlap significantly (e.g., the statement must include a clear compliance status, contact information, and information about inaccessible content due to disproportionate burden). Italy’s AgID has provided an accessibility template for private companies with a three-year average turnover exceeding €500 million (see Linee guida accessibilità Privati and Modello di dichiarazione di accessibilità sito web e applicazione mobile), but they should also ensure their statement covers the specific requirements outlined in Annex V of the EAA.
On April 29, 2025, AgID issued the Guidelines on the Accessibility of Services (see Linee Guida sull’accessibilità dei servizi in attuazione dell’art. 21 d. lgs. n. 82 del 2022), in implementation of Article 21 of Legislative Decree No. 82 of 2022. These guidelines align with the requirements of the European Accessibility Act (EAA) and provide guidance on accessibility by design, including references to both international and national harmonized standards.
Italy’s implementation follows the EAA’s exemption for microenterprises (defined as businesses with fewer than 10 employees and a turnover of less than €2 million). Microenterprises are not required to provide an accessibility statement, but they may choose to do so voluntarily to demonstrate their commitment to accessibility.
Small and medium-sized enterprises (SMEs) and larger companies are not exempt and must comply by June 2025.
The EAA requirements become mandatory in Italy starting from 28 June 2025. While some provisions may phase in, businesses should ensure their accessibility statement is live by that date. There is no need to adapt the statement text itself, but be aware of the compliance timeline.
Italy allows existing products/services to continue until this date before requiring updates, so it’s important to have the statement ready for the official deadline.
Italy’s decrees set penalties for non-compliance with accessibility requirements. Under Legge Stanca, violations can incur fines of up to 5% of a company’s turnover. Under the Legislative Decree 82/2022, non-compliance can lead to penalties of up to €40,000.
By ensuring compliance with the accessibility statement template, businesses can avoid these penalties.
The content requirements for Italy are largely the same as those outlined by the EAA; however, some key adaptations must be made for local regulations. These include translating the statement into Italian, providing it in accessible formats (in Italian), and making references to national laws (like D.Lgs. 82/2022) and relevant enforcement bodies.
Italian companies should ensure their accessibility statement is accessible in Italian and published on their website (preferably in the footer). Additionally, the statement should be available in alternate formats upon request.
Lastly, companies should stay updated on any specific guidelines or requirements issued by Italian authorities, such as AgID, as they may release additional details closer to the 2025 deadline. If new guidelines are introduced, businesses should ensure the template is aligned with those changes while maintaining the core requirements outlined in Annex V.
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