# Accessibility Statements That Hurt: What Not to Promise in Yours

Source: https://adaguardhq.com/blog/2026-11-14-accessibility-statement-promises-that-hurt.html

November 14, 2026

*A retailer received an EAA complaint, and the first document the complainant attached was the retailer's own accessibility statement. It claimed the site was fully accessible, listed a widget as the compliance mechanism, and gave no way to report a barrier. The statement was the evidence.*

## What the statement is actually for

The European Accessibility Act has applied since 28 June 2025, and for covered services it requires an accessibility statement: a public document that describes how accessible the service is, how users can report barriers, and how to contact the provider. It is not a marketing page. It is a legal document, and it will be read by regulators, by disability organizations, and by lawyers, in that order. The [first five months of EAA enforcement](2026-11-13-eaa-five-months-in.md) have made the point plainly: the statement is part of the record, and what it promises is what gets tested.

The statement has three jobs. It tells users what works and what does not. It tells them how to get help when something does not work. And it tells the regulator that the provider knows what its obligations are. A statement that does none of the three is not a bad statement. It is a liability, because it proves the provider wrote something without testing anything.

## The three promises that create liability

First, fully accessible. No large site is fully accessible on every page, and claiming it invites a complaint that tests the claim. Conformance with EN 301 549, which incorporates WCAG 2.1 Level AA, gives a presumption of compliance, not a guarantee. The new version of the standard, v4.1.1, published 2 September 2026, moves the benchmark to WCAG 2.2. A statement that claims full compliance against the old version is already out of date.

Second, accessible via our widget. An overlay that claims to make a site compliant creates the liability it promises to remove. The widget does not fix the underlying barriers, the statement now claims the barriers are fixed, and the gap between the claim and the site is the complaint. The [WCAG 2.2 AA checklist](2026-11-12-wcag-2-2-aa-checklist-storefront.md) is the honest alternative: it names the standard and the work, not the tool.

Third, we are committed to accessibility, with no contact, no mechanism, and no date. A commitment without a way to report a barrier is a sentence, not a process. The EAA requires a feedback mechanism. A statement without one fails the requirement on its face.

## What a defensible statement contains

Scope: which services the statement covers, and which it does not. Standard: EN 301 549 and the WCAG version it incorporates, stated precisely. Known limitations: the barriers you know about, with a date for fixing each one. Feedback: a named contact and a way to report a barrier that does not require the user to find the one accessible page on an inaccessible site. And the enforcement body: the national authority a user can complain to if the feedback goes nowhere. Each part is short. Together they describe a provider that tested its site and knows what is left to do.

## The Carrefour lesson

On 4 June 2026 a court in Caen issued the first binding court order under the EAA, against Carrefour France. The company was given six months to make its website and app fully accessible, a penalty of 500 euros a day after that, and 10,000 euros in damages. The case had been filed the previous November by two disability organizations. It was not the first enforcement action. Sweden's Post and Telecom Authority opened 28 supervisory cases against e-commerce sites in October 2025 on its own initiative. The Dutch regulator made self-reporting mandatory from 15 October 2025. As of mid-2026 no monetary fines had been confirmed under the EAA, but the court order exists, the deadline lands in early December 2026, and the ceiling is set in national law now, whether or not it has been tested in your jurisdiction. The statement you publish today is the document that case will quote.

## Frequently asked questions

### Does the EAA require an accessibility statement?

If you sell covered products or services to EU consumers and you are not a micro-enterprise, yes. The EAA requires an accessibility statement that describes the accessibility of the service, how users can report barriers, and how to contact you. Micro-enterprises, fewer than ten employees and under two million euros in turnover, are exempt from most of the EAA.

### Does claiming WCAG conformance in my statement protect me?

No. Conformance with EN 301 549, which incorporates WCAG 2.1 Level AA, gives a presumption of compliance, but it is a presumption, not a guarantee. A statement that claims full compliance invites a complaint that tests the claim, and no large site is fully compliant on every page.

### Should the statement list known accessibility problems?

Yes, and it should list them. A statement that names known limitations, with a date for fixing them and a way to report new ones, is more defensible than a statement that claims perfection. The limitations section is where the statement proves it was written by someone who tested the site.

### How often should the statement be updated?

Immediately, and with a date. The statement is a living document: every remediation, every new barrier found, and every change to the feedback mechanism should be reflected in it. A statement that still describes the site as it was two years ago is worse than no statement, because it is evidence of neglect.