Annex V · O. Reg. 191/11 · UK procurement practice
Accessibility statement requirements: the six elements, and what each is for.
Requirements pages usually restate the law and leave the reader no better off. This one does the opposite: it takes the six required elements, says what each is meant to achieve, shows how each is normally failed, and explains what an authority or a buyer actually does with it. Everything here applies to the EU model; where Ontario and the UK differ, that is marked.
Signed in five business days, with a public verification code.
Element one: what the statement is about
Each of the six sections below follows the same shape: what the element is meant to achieve, and the way it is normally failed.
The opening names the service, the operator and the exact address. It sounds trivial and it decides everything downstream, because a statement about “our websites” covers none of them precisely and cannot be checked against anything.
The common failure is a group statement published once and linked from six different brands, each with different templates and different problems. When a complaint arrives about one of them, the document describes an average of things rather than the site the complainant used.
Element two: how the requirements are met
This is a description, not a claim, and the distinction is the whole document. A description says what was tested, with which assistive technology, on which dates and across which pages. A claim says the site conforms.
Descriptions can be verified and therefore have value. Claims cannot, which is why an experienced reader skips straight past them to look for the method sentence, and why its absence is read as an answer in itself.
Element three: what does not conform
This is the element that separates a document written after testing from one written after a meeting.
Every jurisdiction that requires a statement requires this part, and it is the one organisations resist hardest. The instinct is that naming problems invites trouble. In practice the opposite is true: a named barrier with an alternative and a date is a managed position, while an undisclosed barrier discovered by a user is an ambush for both sides.
| Way it fails | What the reader concludes |
|---|---|
| Section omitted entirely | Either perfection, which nobody believes, or no testing |
| Vague wording: “some content may not be accessible” | Somebody suspects a problem and did not look |
| Forty items listed without priority | Thorough, unreadable, and the important ones are lost |
| Third-party components blamed without detail | Responsibility is being moved rather than managed |
| Named honestly, with alternative and quarter | This organisation knows its own service |
Element four: the alternatives
The element that decides whether the previous one reads as responsible or as an admission.
An alternative is what the person does today, not what you will build next year. A phone number that is answered, an email address that produces an order, an accessible version of a document on request, a staffed channel that knows the alternative exists.
Two mistakes recur. The alternative is a queue during office hours while the online route is open at midnight, which reduces the disadvantage rather than removing it. Or the alternative is published and never communicated internally, so the first person to use it reaches a colleague who has never heard of it.
Element five: the feedback mechanism
Of the six, this is the one most likely to be tested by a stranger within a week of publication.
This is the element regulators test first, because it is the only one they can test without opening your site. They write to the address and see what happens.
It needs three properties. Reachable: an address or form that works and is findable from the statement. Owned: it arrives with a named person, not a shared mailbox nobody reads. Answered: within the time the statement promises, which is why the promise should be a time you can keep in August as well as in February.
Element six: date and review
The shortest element, and the one that decides whether the other five are believed.
A statement without a date is read as an old statement. A statement promising periodic review is read as one that will not be reviewed. The credible version gives the date of the last review and the rhythm: monthly, quarterly, whatever you actually do.
This is also where most published statements decay. The document was accurate in March, the theme changed in May, and by August it describes a website that no longer exists — which is a worse position than silence, because it is a published claim contradicted by the live service.
Where the three jurisdictions differ
Useful if you sell into more than one of them, which most of our clients do.
The six elements hold everywhere we work. Three things change with the market.
The standard cited. WCAG 2.2 AA in the EU and the UK by convention; in Ontario the legal reference is WCAG 2.0 AA under O. Reg. 191/11, and testing at 2.2 exceeds it. The details are on the Ontario page.
The escalation route. The national enforcement body in the EU, the provincial reporting route in Ontario, and the Equality Act complaint path in Britain, described on the UK page.
Who signs. Europe Services SE for the Union, REP27 LTD for the United Kingdom, Goldman Services INC for Ontario, each established where the obligation sits.
What a reader does with the document
Statements are written for regulators and read by three different groups. Only one of them is a regulator.
Three audiences, three reading patterns, and knowing them changes how you write.
A user who hit a barrier scans for the open issues and the alternative, and decides in ten seconds whether this organisation is likely to help. They do not read the conformance paragraph.
A buyer in procurement checks the date, the method sentence and the honesty of the exceptions, then moves on. A statement claiming perfection triggers a demo account and a five-minute test by somebody who knows where to look.
An enforcement body asks for the evidence behind the text and the reply given through the feedback channel. The document is the entry point; the file behind it is the answer.
How we produce one
The order matters, and it is the opposite of how most statements are produced.
The audit comes first, because elements two and three cannot be written without it: automated pass, then manual testing with keyboard and screen reader across your real flows, at 400 percent zoom and at narrow widths, including areas behind a login when you provide access.
The statement is then written from the findings, in the structure the applicable law requires, in the language of your market, signed by the company established in your jurisdiction and issued with a public code anyone can verify. Alongside it you receive the findings report, the hosted feedback channel, monthly re-testing and five years of records.
690 € a year for the European Union, 890 CAD for Canada, 1,290 € for three domains and six languages, 1,990 € for all three regions with one renewal date. Five business days from a complete form, seven days free with no card.
A checklist for a statement you already published
Most organisations arriving here already have something online. This is how to judge it in ten minutes.
If a statement is already online, you do not need to rewrite it from scratch. Nine questions tell you whether it holds.
- Does it name the exact address it covers, rather than the organisation in general?
- Does it carry a review date from this year?
- Does it name the standard with version and level?
- Does it say how the assessment was carried out, with dates and technologies?
- Does it say who carried it out, internally or externally?
- Does it list the parts that do not conform, in language a customer understands?
- Does each open item have an alternative that works today?
- Does the feedback address reach a named person with a stated reply time?
- Does it say when it will next be reviewed, in terms you actually follow?
Three or more noes and the document is decoration rather than compliance. That is not a disaster: it is the normal starting point, and the repair is testing followed by a rewrite of two paragraphs.
The two paragraphs that carry the weight
If you take one thing from this page, take this.
Everything else can be written by anyone. Elements two and three cannot, because they are the only parts that make an assertion about your specific website, and both of them require somebody to have opened it and worked through it. That is the entire reason templates and generators fall short: not because the wording is poor, but because the two paragraphs that matter are the two they cannot fill.
It is also the reason a statement is cheap to maintain once it exists. The structure never changes, the contact details rarely change, and the standard changes every few years. What changes monthly is the content of those two paragraphs, and that is exactly what a re-test produces.
Requirement questions
What must an accessibility statement contain?
A description of the service, how it meets the requirements, the parts that do not, the alternatives offered, a working feedback route and a date.
Is the format prescribed?
In the EU the content is prescribed by Annex V, not the layout. Public sector bodies follow their own model.
How long should it be?
One page. Length usually comes from quoting the standard instead of describing the site.
Do I have to name the standard?
Yes, with version and level. WCAG 2.2 level AA, or WCAG 2.0 level AA where Ontario law applies.
Do I have to disclose problems?
Yes. The non-conforming parts are a required element, not an optional confession.
What counts as an alternative?
A route that lets the person complete the task now: a phone line, an email, an accessible export, a human channel.
What makes a feedback mechanism valid?
It is reachable, it reaches a named person, and the stated reply time is met.
Does the statement need a date?
Yes, and a review commitment you can keep.
Where should it live?
At a stable address linked from every page, so it survives redesigns and can be cited.
Must it be in the local language?
If you serve consumers in a country, the statement should be available in that language.
Who should prepare it?
Anyone can write it. External testing behind it is what makes it evidence rather than assertion.
Is a verification code required?
No, but it lets a buyer or authority confirm the document without contacting you.
How often must it be updated?
On material change and at least annually. Our plan re-tests monthly.
What happens if it is wrong?
A statement contradicted by two minutes of testing turns a technical issue into a credibility problem.
Does an app need one?
If the app delivers a covered service, yes, with the technical references adapted.
Can one statement cover several sites?
Only if it describes them accurately. Different sites usually need different statements.
What does a signed statement cost?
690 € a year for the EU, 890 CAD for Canada, 1,290 € for three domains, 1,990 € for all three regions.
How fast can I have one?
Five business days from a complete form, with seven days free and no card.