The EU accessibility statement template for an EAA-bound SMB, annotated clause by clause

Why the EAA borrows the Web Accessibility Directive's template

The Web Accessibility Directive — Directive (EU) 2016/2102 of 26 October 2016 on the accessibility of websites and mobile applications of public-sector bodies — was the EU's first horizontal accessibility instrument with a substantive transparency obligation. Under Article 7 of that directive, every public-sector body covered by it has to publish an accessibility statement on its website. To make those statements comparable across member states (the Commission's first periodic application report under Article 8 was due 2022 and ran on aggregated statement data), the Commission issued Implementing Decision (EU) 2018/1523 of 11 October 2018, which contained an Annex setting out a model accessibility statement that public-sector bodies were strongly encouraged to use. The annex is the canonical 12-clause template.

When the EAA was being drafted in 2017-2019 and finalised as Directive (EU) 2019/882, the working assumption was that the substantive obligations on private-sector economic operators would mirror the public-sector ones already in flight under the WAD. The text of the EAA does not reproduce the 12-clause template verbatim — instead, Article 13 of the EAA requires service providers to "make publicly available [...] in writing and orally [...] in an accessible manner" information about the service, including how it meets the accessibility requirements, and Annex V of the EAA sets out what that information has to contain. The relationship between Annex V and the 2018/1523 template was clarified in the Commission's transposition guidance and in every major member-state transposition: the public-sector 12-clause template satisfies Annex V of the EAA when extended with the Article 14 disproportionate-burden documentation and (where invoked) the Article 4(5) microenterprise documentation. That extension is the operating instruction for every SMB writing its first statement.

The mechanical consequence: an EU SMB writing its EAA statement does not need to invent a structure. The 12 clauses below come from 2018/1523 directly, and the two additional clauses (13 and 14) come from EAA Annex V read with Articles 14 and 4(5). The member-state transpositions set out below add national-language and contact-point requirements on top.

The 12 mandatory clauses, annotated

Each clause below sets out (a) what the template requires verbatim from 2018/1523, (b) what an EAA-bound SMB has to add or change to make the clause carry the EAA-specific weight, and (c) the captioning-specific evidence to file in that clause. The captioning-evidence column is the one most SMBs miss.

Clause 1 — Compliance status

What 2018/1523 requires: A statement that the website / mobile application / service is "fully compliant," "partially compliant," or "non-compliant" with the requirements of the relevant directive, with a brief reason where partial or non-compliance is claimed. The legal terminology in the original is "wholly conformant," "partially conformant," and "non-conformant," with the comparison standard being EN 301 549.

What the EAA adds: The comparison standard is still EN 301 549 V3.2.1 (the version cited in the harmonized-standards process for the EAA), but the operative text should reference EN 301 549 by clause and WCAG 2.1 Level AA by Success Criterion. For an SMB that ships training video, the operative reference set is EN 301 549 clause 7.1 (caption playback) read with WCAG 2.1 SC 1.2.1 (Audio-only and Video-only — Prerecorded), SC 1.2.2 (Captions — Prerecorded), SC 1.2.4 (Captions — Live), and SC 1.2.5 (Audio Description — Prerecorded).

Captioning evidence to file: The compliance status for each audiovisual surface separately. A common SMB pattern is "wholly conformant" for newly-produced video shipped after 2026-Q1 and "partially conformant" for the back-catalogue, with the back-catalogue retrofit timeline filed in clause 7. Do not put a single "partially compliant" wrapper over all surfaces — that is the hardest claim for a surveyor to validate and the easiest to challenge.

Clause 2 — Preparation of the statement

What 2018/1523 requires: A description of how the statement was prepared — the assessment method, the identity of the assessor (in-house or external), and the date of the assessment.

What the EAA adds: Clause 11 below covers the conformance review method; clause 2 covers the higher-level preparation — who in the organisation owns the statement, when the assessment ran, and what the assessment scope was. For an SMB the realistic answer is "in-house assessment by the head of L&D / engineering / customer success on [date], with caption-quality scoring by [external vendor] for [N] sample assets." The named role matters; the surveyor will ask whether that role still exists on the org chart and whether the named individual is still in it.

Captioning evidence to file: The sampling plan — which assets were sampled, by what mechanism (random across catalogue, weighted toward high-traffic, weighted toward high-regulatory-risk), and what proportion of total minutes were sampled. A statement that says "100% of catalogue assessed" without a vendor receipt is the second-easiest to challenge after the wrapper claim. A statement that says "20% sample, weighted toward [criteria]" with the caption-quality scores attached as a public artifact is a defensible claim a surveyor will accept.

Clause 3 — Feedback and contact information

What 2018/1523 requires: A mechanism by which a user can notify the body about non-compliance, and a mechanism by which a user can request information that has been excluded under a disproportionate-burden invocation in an accessible alternative format. The mechanism must include the postal address, an email address, and where applicable a telephone number; the contact person or unit must be named; the response time has to be reasonable.

What the EAA adds: The feedback mechanism is one of the explicit Article 13 EAA obligations and is also the most-policed clause across member states. The mechanism has to actually work; an autoresponder followed by an unmonitored inbox is a finding in its own right. The response-time floor most member states have published guidance on is 30 days, with several (Germany, France) requiring an interim acknowledgement within a shorter window.

Captioning evidence to file: The exact feedback channel, the named person responsible, and the time-bound commitment. Example operative text: "Email accessibility@example.com, monitored by [name, role], 7-day acknowledgement window, 30-day substantive response window. To request a captioned version of a video that does not currently have captions, include the asset URL or LMS course ID."

Clause 4 — Enforcement procedure

What 2018/1523 requires: Identification of the national enforcement procedure, including a link or contact for the body that handles complaints when the user is not satisfied with the response received under clause 3. This is the regulator the user can escalate to.

What the EAA adds: Under the EAA the enforcement body is the national market-surveillance authority designated under Article 19. The authority differs by member state (Germany: Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen — a single coordinating authority, MLBF, with state-level branches; France: DGCCRF; Italy: AgID for digital services and AGCOM for audiovisual; Spain: OADIS plus the autonomous-community equivalents; Netherlands: ACM with the College voor de Rechten van de Mens for individual complaints). The statement must list the relevant authority for each member state in which the service is offered.

Captioning evidence to file: Just the authority — clause 4 is purely a contact-information clause and is not the place for substantive content. Get the authority list right; a statement that omits the relevant authority in a member state where the service is offered is a per-member-state finding.

Clause 5 — Name of the body

What 2018/1523 requires: The legal name of the body the statement covers.

What the EAA adds: The legal name of the economic operator placing the service on the market, plus (where relevant) the trading name and any subsidiary names. For an SMB whose legal entity name differs from the brand the customer knows ("BlueRiver Digital Learning S.r.l." trading as "RiverLearn"), include both. The Italian, Spanish and German transpositions have all flagged the legal-name / trading-name divergence as a discoverability risk and require both to appear.

Captioning evidence to file: No captioning evidence — clause 5 is administrative. But verify the spelling against the official register in each member state of operation; a misspelled legal name in the company register is treated as a separate finding under Spain's Real Decreto 193/2023.

Clause 6 — Accessible content and inaccessible content

What 2018/1523 requires: A list of the parts of the website / mobile application / service that are not accessible, the reasons, and the schedule for making them accessible. Clause 6 is the substantive heart of the statement.

What the EAA adds: Under the EAA every audiovisual surface is potentially in scope. The statement has to enumerate, by category (not by individual file — an SMB with a 1,200-asset back catalogue does not enumerate each), what is and is not accessible. Categories the major member-state authorities have identified as the right granularity: (a) live training content, (b) prerecorded training content shipped before [cutoff date], (c) prerecorded training content shipped after [cutoff date], (d) marketing and product video on the public website, (e) onboarding video inside the product, (f) help-center video. For each category the operative text states the conformance status and (where partial or non-conformant) the specific Success Criterion that fails and the reason.

Captioning evidence to file: Per-category caption-quality reporting. Example: "Live training content (category a): non-conformant against SC 1.2.4. We do not currently caption live sessions. Alternative provided per clause 8: every live session is recorded, captions added within 7 days, recording made available on demand. Prerecorded training shipped after 2026-01-01 (category c): wholly conformant against SC 1.2.2. Prerecorded training shipped before 2026-01-01 (category b): partially conformant. 412 of 814 assets fully captioned, the remaining 402 are scheduled for retrofit by 2026-09-30. The retrofit prioritisation is documented in the Article 14 disproportionate-burden assessment attached at clause 13."

Clause 7 — Disproportionate-burden invocations (under WAD Article 5)

What 2018/1523 requires: Where the body claims that meeting some part of the accessibility requirement would impose a disproportionate burden under Article 5 of the WAD, the statement must say so, identify which content is affected, and refer to the assessment that supports the invocation.

What the EAA adds: The EAA's disproportionate-burden mechanism is at Article 14, with the assessment criteria laid out in Annex VI. The statement must reference each invocation by content category (matching clause 6's categorisation), give a one-sentence reason, and link to the Article 14 / Annex VI assessment in clause 13. Member-state authorities have published guidance saying that a disproportionate-burden invocation that does not link to a written assessment is treated as no invocation at all — the content is treated as in-scope and non-conformant.

Captioning evidence to file: One disproportionate-burden invocation per content category where retrofit is being deferred. For an SMB the most common invocation is "back-catalogue captioning of pre-2024 content where the source-language audio is below studio quality; full retrofit estimated at €N and N-person-months against an annual revenue of €Y." The assessment in clause 13 has to actually run the math.

Clause 8 — Alternative accessible solution where applicable

What 2018/1523 requires: Where content is excluded under clause 7, the body has to describe an alternative accessible solution it will provide on request, and the contact mechanism for requesting it.

What the EAA adds: The EAA strengthens the alternative-solution requirement: the alternative has to be "equivalent" or as close as the disproportionate burden allows. For audiovisual content the realistic alternatives are (a) a full transcript made available within a stated turnaround, (b) on-demand captioning of a specific asset on user request within a stated turnaround, (c) a sign-language interpretation as a second video track. Most SMBs ship (a) and (b); (c) is rare except in Germany where BFSG section 4 makes sign-language the default expectation for "essential" content.

Captioning evidence to file: The alternative service — exactly what is offered, exactly how to request it, and the turnaround time. Example: "On-demand captioning of any back-catalogue video: 7-business-day turnaround. Email accessibility@example.com with the asset URL or LMS course ID. Captions delivered as an SRT or VTT sidecar, with the asset re-uploaded to the LMS by us, or sent to you for upload, at your option."

Clause 9 — Date the statement was prepared

What 2018/1523 requires: The date on which the statement was originally prepared.

What the EAA adds: Same. Use ISO 8601 (YYYY-MM-DD); some member-state authorities (Germany, Netherlands) have flagged ambiguous date formats as a finding.

Captioning evidence to file: No captioning evidence — purely administrative.

Clause 10 — Date the statement was last reviewed

What 2018/1523 requires: The date of the most recent review. The directive sets no fixed review cadence but the implementing decision recommends "at least annually" and after any substantive change.

What the EAA adds: Member-state authorities have set their own minima. Germany's BFSG requires "at least annual" review and a re-review on any substantive change. Italy's Decreto Legislativo 82/2022 sets a quarterly review minimum for AgID-monitored services. France's Décret n° 2019-768 sets annual review with re-review on substantive change.

Captioning evidence to file: No captioning evidence — but a stale review date (more than 12 months old, or more than 90 days old in Italy) is itself a finding. The review must be substantive; "re-published with no change" without a documented re-assessment is challengeable.

Clause 11 — Conformance review method

What 2018/1523 requires: Identification of the method used to assess conformance. The directive lists three: self-assessment, third-party assessment, or external monitoring by the supervising authority.

What the EAA adds: For an SMB writing its first statement the realistic answer is "self-assessment by [role] using [tool / methodology], with sample-based third-party validation by [external vendor] for caption-quality scoring on a [N]% sample of audiovisual content." Naming the tool — axe DevTools, Wave, Lighthouse, Pa11y, or for captions a DCMP-aligned scoring sheet — strengthens the claim.

Captioning evidence to file: The caption-quality scoring methodology. The reference standard most member-state authorities have flagged as the de facto floor is the DCMP Captioning Key's 99% accuracy target. Cite the methodology by name and the scoring rubric used.

Clause 12 — Name and URL of assistive content where applicable

What 2018/1523 requires: Where the body provides supplementary accessible content (for example, a transcript page next to a video), the URL of that content.

What the EAA adds: Same. For an SMB this clause is where the transcript-page URLs go, the captioning-on-request page goes, and any sign-language-version pages go. If you offer a full transcript page for every prerecorded video, this clause links to the index of those transcript pages.

Captioning evidence to file: The transcript-page index URL or the per-asset transcript-page convention. Example: "Per-video transcripts available at /transcripts/<asset-id>. Index of all available transcripts at /transcripts/."

The two EAA-specific add-on clauses

Clause 13 — Article 14 disproportionate-burden assessment (annexed)

Article 14 of the EAA permits an economic operator to claim that meeting one or more accessibility requirements would impose a disproportionate burden, and to defer or avoid the obligation. The criteria for the assessment are set out in Annex VI of the EAA, which has three substantive limbs:

1. The ratio of the net costs of compliance to the overall costs of providing the service — the cost of accessible-feature implementation against the cost of operating the service overall. The Commission's transposition guidance has clarified that "operating the service overall" means the service the requirement applies to, not the entire enterprise.
2. The estimated costs and benefits for the economic operator in relation to the estimated benefit for persons with disabilities — the cost / benefit balance, with the benefit measured by the population-share of persons with disabilities likely to use the service.
3. The frequency and duration of use of the specific service — a rarely-used service can satisfy the disproportionate-burden test more easily than a daily-driver service.

The assessment template that satisfies Annex VI on a single page:

A handful of points the major member-state authorities have flagged as common errors in published Article 14 assessments:

• Limb 1 with a denominator that is the entire enterprise revenue rather than the service's revenue. The cost of captioning a 1,200-hour back catalogue against the operator's group revenue will always look proportionate; against the revenue of the specific training-video service line it can fail the proportionality test or pass it depending on the line's actual size. Use the service-line denominator, not the enterprise denominator. This is the single most common error in published assessments.
• Limb 2 with a benefit estimate of zero. "We have no users with disabilities" is not an acceptable benefit estimate; the benefit calculation is forward-looking and uses the EU population-share of persons with disabilities (~27% per the 2021 EU-SILC ad-hoc module, ~16% if narrower definitions of severe disability are used). Use the population-share figure, multiplied by the service's reach.
• Limb 3 with no lifecycle reference. Content scheduled for refresh in 6 months is a stronger candidate for the disproportionate-burden test than content with no refresh schedule. Always reference the planned lifecycle.
• No review date. Article 14(3) requires a re-assessment every 5 years or sooner if there is a change in the service that affects the assessment. A static assessment with no review date can be challenged on procedural grounds alone.

Multiple Article 14 assessments are normal and recommended — one per content category where the requirement is being deferred. A single wrapper assessment covering the entire back-catalogue is harder to defend than three or four narrower assessments each addressing a specific subset.

Clause 14 — Article 4(5) microenterprise carve-out documentation

Article 4(5) of the EAA exempts microenterprises (defined as fewer than 10 employees and either an annual turnover or annual balance-sheet total not exceeding €2 million, in the Commission Recommendation 2003/361/EC sense) that provide services from the substantive accessibility requirements. The exemption does not apply to microenterprises that produce or place products on the market — those have a lower-effort consultation obligation but no carve-out from the substantive obligations.

If the carve-out is being claimed, the statement must document it. The template:

A few points the major member-state authorities have flagged as common errors in published microenterprise documentation:

• Headcount that excludes contractors or seconded staff. Commission Recommendation 2003/361/EC counts annual work units (AWU) — full-time equivalents at the close of the reference year — and includes working owners, partners engaging in regular activity, and family members participating in the activity. It excludes apprentices on contract, but not regular long-term contractors who are de facto staff. Several authorities have challenged headcount figures that omit the working-owner.
• Turnover OR balance sheet, not both. The threshold is a Boolean OR — meet either, not both. A microenterprise with €1.8M turnover and €2.5M balance sheet still qualifies. A microenterprise with €2.5M turnover and €1.8M balance sheet still qualifies.
• Linked / partner enterprise rules. The Commission Recommendation includes calculation rules for linked and partner enterprises — broadly, if the operator is owned 25%-49% by a larger enterprise, a partial pro-rata of the larger enterprise's headcount and finances is added; if owned 50%+, the full figures are added. A microenterprise owned by a non-microenterprise group will usually fail the threshold once the linked/partner rules are applied. Document the corporate structure.
• The two-financial-years rule for crossing the threshold. A microenterprise that crosses the threshold in one financial year but does not cross it in the prior year retains the exemption for that year. The exemption is lost only when the threshold is crossed in two consecutive financial years (Article 4 of the Commission Recommendation). This means a fast-growing microenterprise has a one-year buffer; document the year-by-year figures so the buffer is provable.

The microenterprise carve-out is real and meaningful, but it is much narrower than EU SMB founders typically assume — in particular it does not cover the 10-49 employee tier that EU policy still labels "small," and it does not cover any operator that places products on the market. A 12-person company is fully in scope; a microenterprise of 9 employees that grows to 12 in calendar 2026 retains the exemption for 2026 (because the threshold has only been crossed once) but loses it for 2027 if headcount stays above the threshold. Plan around the buffer.

Member-state variations on the template

The 12-clause template plus the two EAA add-ons is the union, but each major member state has layered its own additional requirements on top. The five transpositions below cover the largest EU markets and the variations most likely to catch an SMB.

Germany — Barrierefreiheitsstärkungsgesetz (BFSG)

The BFSG was passed on 16 July 2021 and took effect 28 June 2025 alongside the underlying directive. The implementing regulation, the Barrierefreiheitsstärkungsgesetz-Verordnung (BFSGV), was finalised in 2022 and contains the technical-detail framework. Two BFSGV clauses materially change the accessibility statement template:

• Section 4 BFSGV — easy-language and sign-language presentation. The accessibility statement itself must be available in Leichte Sprache (a controlled-vocabulary easy-language register defined by the Netzwerk Leichte Sprache and the Bundesministerium für Arbeit und Soziales) and as a Deutsche Gebärdensprache (DGS) signed video. Both the easy-language version and the signed-video version are mandatory artifacts; the standard-language statement alone is not sufficient. The DGS video is a non-trivial production — most operators commission it from one of the established DGS production studios (Gebärdenwerk, Yomma, Nicom, GIB Gebärdenwerk, etc.) at €1,000–€3,000 per minute.
• Section 5 BFSGV — fine schedule. Fines under the BFSG run up to €100,000 per violation. The "per violation" quantifier has been clarified by the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF) as per-finding-per-service, not per-affected-asset. A single Section 4 BFSGV breach (no easy-language version) on a single service is one €100,000 ceiling, not one ceiling per asset. The €100,000 figure is the legislative ceiling; in practice MLBF guidance has indicated that first-time findings on SMBs will be in the four-to-five-figure range.

Operating consequence: a German SMB writing its statement needs three artifacts (standard-language statement + Leichte-Sprache version + DGS signed video) and needs to budget for the DGS video production. The MLBF has indicated that the DGS video can be produced in-house if the operator employs a qualified DGS interpreter, but the realistic path for SMBs is external production.

France — Loi n° 2023-171 du 9 mars 2023 and Décret n° 2019-768 du 24 juillet 2019

France transposed the EAA via Loi n° 2023-171 of 9 March 2023, which amended the Code de la consommation and several adjacent codes. The accessibility-statement-specific obligations sit in the older Décret n° 2019-768 of 24 July 2019 (the WAD transposition) which has been extended to cover EAA-bound private operators. Two clauses materially change the template:

• Article 6 of Décret n° 2019-768 — multi-year accessibility plan reference. The statement must reference, by URL, the schéma pluriannuel de mise en accessibilité (multi-year accessibility plan) covering the operator's services. The plan is a separate document with a 3-year horizon, broken into annual action plans. The statement and the plan have to be cross-referenced.
• DGCCRF response-time clock — 7 days. The Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF), the French market-surveillance authority for consumer-facing services, has published guidance setting an interim acknowledgement deadline of 7 days for accessibility complaints (separate from the 30-day substantive response window in the implementing decision). The statement must commit to the 7-day acknowledgement explicitly.

Operating consequence: a French SMB writing its statement also has to write the multi-year accessibility plan (a 3-page minimum, structured as goals + annual actions + named owners) and link to it from clause 12 of the statement. The 7-day acknowledgement clock has to be operationalised — autoresponders count for this, but the substantive response within 30 days has to be from a human.

Italy — Decreto Legislativo 27 maggio 2022 n. 82

Italy transposed the EAA via Decreto Legislativo 27 maggio 2022 n. 82, which assigned market-surveillance to AgID (Agenzia per l'Italia Digitale) for digital services and AGCOM (Autorità per le Garanzie nelle Comunicazioni) for audiovisual media services access. The Italian transposition adds three template requirements:

• AgID format specification. AgID has published a standardised JSON format for accessibility statements (the Modello di dichiarazione di accessibilità) that operators must publish at a well-known URL — /.well-known/accessibility-statement.json — in addition to the human-readable HTML statement. The JSON format is a structured machine-readable representation of the same 12 clauses.
• Quarterly review minimum. Decreto Legislativo 82/2022 requires a substantive review of the accessibility statement at least once per quarter for AgID-monitored services, with the review date logged in clause 10. A statement with a clause-10 review date older than 90 days is a finding.
• AGCOM jurisdiction split. If the service includes audiovisual media services access (the EAA's specific category — see Article 2(2)(b)), AGCOM is the relevant authority and must be listed in clause 4 in addition to AgID. Most training-video services trigger this split.

Operating consequence: an Italian SMB writing its statement publishes two artifacts (the HTML statement at /accessibility and the JSON statement at /.well-known/accessibility-statement.json) and runs a quarterly review cadence. The JSON format is well-documented in the AgID developer guidance and is mostly a serialisation of the HTML statement; the operational cost is the quarterly review, not the JSON production.

Spain — Real Decreto 193/2023

Spain transposed the EAA via Real Decreto 193/2023 of 21 March 2023, which assigned national-level coordination to OADIS (Oficina de Atención a la Discapacidad) and explicitly retained autonomous-community-level enforcement powers. The Spanish transposition adds two template requirements:

• Autonomous-community contact in clause 4. In addition to OADIS as the national authority, the statement must list the relevant autonomous-community accessibility authority for each region in which the service is offered to consumers. The 17 autonomous communities each have their own designated authority; the most active to date are Catalonia (Direcció General d'Inclusió Social) and the Basque Country (Departamento de Igualdad, Justicia y Políticas Sociales). For an SMB offering service across Spain, the practical move is to list OADIS plus a generic reference to "the autonomous-community accessibility authority of the user's region."
• Spanish-language obligation. The statement must be in Castilian Spanish at minimum. If the service is offered in Catalan, Galician, Basque or Valencian, the statement must also be in those languages — not as a translated supplementary version, but as primary content. Real Decreto 193/2023 article 14 has been read by the Departament de Cultura de Catalunya as requiring full-statement-in-Catalan for any service offered to Catalan-speaking consumers.

Operating consequence: a Spanish SMB writing its statement publishes a Castilian-Spanish version at minimum, plus one or more regional-language versions if the service reaches Catalan / Galician / Basque / Valencian consumers. The contact list in clause 4 has to be region-aware.

Netherlands — Implementatiewet toegankelijkheidsvoorschriften producten en diensten

The Netherlands transposed the EAA via the Implementatiewet toegankelijkheidsvoorschriften producten en diensten, in force since 28 June 2025, with market-surveillance assigned to Autoriteit Consument & Markt (ACM) for the substantive obligations and the College voor de Rechten van de Mens for individual complaints. The Dutch transposition adds two template requirements:

• Article 2 Implementatiewet — Dutch-language obligation. If the service is offered to Dutch consumers, the accessibility statement must be in Dutch. English-only statements are not sufficient even where the service is offered in English. The ACM has published guidance saying that an English statement with a Dutch summary is the realistic minimum for SMBs that operate primarily in English.
• Fine schedule — €900,000 or 1% of annual worldwide turnover. The Dutch fine schedule is the highest in the major-member-state set, with a per-violation ceiling of €900,000 or 1% of annual worldwide turnover, whichever is greater. ACM has indicated that first-time findings on SMBs will be in the lower five-figure range; the ceiling is reserved for repeat offences and large operators.

Operating consequence: a Dutch-market SMB writing its statement produces a Dutch version (full or substantial summary) and sets a budget line for the higher fine ceiling.

Other member states — quick reference

The five transpositions above cover the largest member-state markets. The other twenty-two transpositions follow the 2018/1523 template more closely with smaller national-level additions. A quick reference to the clause-affecting variations:

• Austria: Bundesgesetz über die Barrierefreiheit von Produkten und Dienstleistungen (BaSG). Adds an Austrian Sign Language (ÖGS) recommendation but not a mandate. National authority: Sozialministeriumservice.
• Belgium: Loi du 28 octobre 2024 / Wet van 28 oktober 2024. Trilingual statement obligation (French, Dutch, German for the German-speaking community) for any service offered to Belgian consumers. National authority: SPF Économie / FOD Economie.
• Denmark: Lov nr. 801 af 7. juni 2022 om tilgængelighed af varer og tjenester for personer med handicap. Danish-language obligation. National authority: Digitaliseringsstyrelsen for digital, Sikkerhedsstyrelsen for products.
• Finland: Laki saavutettavuusvaatimuksista. Bilingual Finnish/Swedish obligation. National authority: Etelä-Suomen aluehallintovirasto.
• Ireland: European Union (Accessibility Requirements of Products and Services) Regulations 2023 (S.I. No. 636 of 2023). English-language sufficient (Irish-language version recommended for state-funded services). National authority: National Disability Authority for guidance, Competition and Consumer Protection Commission for enforcement.
• Poland: Ustawa z dnia 26 kwietnia 2024 r. o zapewnianiu spełniania wymagań dostępności. Polish-language obligation. National authority: PFRON-supervised market-surveillance.
• Portugal: Decreto-Lei n.º 82/2022. Portuguese-language obligation. National authority: ANACOM for digital services with audiovisual scope; Direção-Geral do Consumidor for general consumer services.
• Sweden: Lag (2023:254) om vissa produkters och tjänsters tillgänglighet. Swedish-language obligation. National authority: Myndigheten för digital förvaltning (DIGG) for digital, Konsumentverket for general consumer services.

The pattern is consistent: every member state with an official national language requires the statement in that language; a handful (Belgium, Finland, Spain, Catalonia/Basque Country) require multiple-language versions; the Nordic and Western-European member states tend toward the higher fine ceilings; the Mediterranean member states tend toward more prescriptive technical-format requirements (Italy's JSON format being the clearest example).

The feedback mechanism — operationally

Of the 14 clauses, the feedback mechanism in clause 3 is the one most-frequently cited in member-state-authority enforcement decisions to date. The pattern is consistent across Germany, France, Italy and Spain: a clause-3 mechanism that is technically present (an email address listed) but operationally broken (no monitored inbox, no acknowledgement, no substantive response within the stated window) is treated as the same finding as the absence of a mechanism. The MLBF in Germany has gone further and treated such a mechanism as aggravating rather than mitigating — the operator made a representation in the statement that turned out to be false, which is a stronger finding than no representation at all.

The operational checklist for an SMB:

1. The inbox is monitored by a real human. An autoresponder for the 7-day acknowledgement clock is fine; the substantive response within 30 days has to be human-authored.
2. The named role is filled. If clause 3 names "the Head of Customer Success" as the responsible person and the role is currently vacant, the statement is stale and must be updated.
3. The acknowledgement is sent within the stated window. The DGCCRF's 7-day window is the strictest published. Default to 7 days everywhere.
4. The substantive response addresses the request. A response that says "we will look into this" is not substantive; the response must say what is being done, by when, and by whom.
5. A log of feedback received and responses sent is kept. Most member-state authorities will request the log on a spot-check. A simple spreadsheet with date-received, requestor, request-summary, acknowledgement-date, response-date, response-summary is sufficient.
6. Repeat or pattern requests are escalated to clause 6. If multiple users request captioning of the same back-catalogue category, that pattern feeds the next clause-6 review and the next Article 14 assessment. The feedback mechanism is the source of truth for operator-side prioritisation, not just a complaint inbox.

The realistic operating cost for an SMB in the 50-200 employee tier: a half-day per month on average for the named owner, with peak demand around major content launches and around the periodic-review cycle. Most SMBs that have been running a real feedback mechanism for 6+ months report 0-5 substantive accessibility requests per month per 1,000 active users; the volume is small, but the responsiveness signal carries.

The periodic-review cycle — operationally

The 2018/1523 implementing decision recommends "at least annual" review. The realistic cadence for an EAA-bound SMB is:

• Quarterly if operating in Italy (AgID minimum) or running content that changes monthly.
• Annually in every other member state, with re-review on substantive change to the service.
• Within 30 days of any of: (a) a new audiovisual surface launching, (b) a back-catalogue retrofit milestone landing, (c) a feedback-mechanism request that surfaces a new non-conformance category, (d) a member-state guidance update that materially changes any of the 12 clauses, (e) a corporate-structure change that affects the microenterprise calculation.

The substance of a periodic review: re-run the conformance assessment from clause 11 against a fresh sample, update clauses 1, 6, 7, 8, 10, and the Article 14 assessment in clause 13, log the date in clause 10, and re-publish. The review log itself does not need to be public, but most operators publish a short changelog at the bottom of the statement page summarising what changed in each review. The changelog format that several member-state authorities have flagged as exemplary:

The discipline that keeps the cadence honest is putting the review date on the team's shared calendar. A 30-minute periodic-review meeting on the calendar 12 months out from publication is the operational difference between a statement that ages well and one that becomes a finding.

The downloadable annotated template — copy and adapt

The full annotated template below is yours to copy verbatim into your own statement page. Replace every bracketed placeholder with content specific to your service, member states of operation, and corporate structure. Publish at /accessibility (the de facto well-known path adopted by every major member state's published exemplar statements). For Italian-market services additionally publish the JSON serialisation at /.well-known/accessibility-statement.json.

Two implementation notes. First, the statement is more useful in plain HTML than in a PDF — the WCAG 2.1 Level AA conformance of the statement itself is the surveyor's first check, and an HTML page authored against the same standard the statement claims is the lowest-friction path. Second, the statement page should be linked from the footer of every page in the service, not just from a buried "About" page; member-state guidance has consistently flagged statement-page discoverability as a quality signal.

The OCR HIPAA / ADA Title II / EAA cross-walk for an EU-and-US-operating SMB

An EU SMB that also operates in the US — common for SaaS scale-ups — has to satisfy three accessibility regimes simultaneously: ADA Title II in the US for any state-or-local-government customer, Section 504 for any federal-financial-assistance customer, and the EAA in the EU for any consumer-facing service. The accessibility statement is one of the few artifacts that can do double duty across all three. The cross-walk:

• The 12-clause EU template covers most of the ADA Title II requirement. ADA Title II does not have a prescriptive statement template, but the DOJ's Title II web-content rule (28 CFR Part 35 Subpart H) requires the same substantive disclosures: scope of accessibility commitment, conformance status, contact mechanism, complaint procedure. Filing a single statement that satisfies the EU template will typically over-satisfy the ADA Title II disclosure expectation.
• Section 504 adds the federal-financial-assistance lens. A Section 504-bound operator (e.g., a SaaS that contracts with public universities) should add a clause-1 reference to Section 504 alongside the EU citation, and a clause-4 reference to the relevant federal enforcement office — typically the Office for Civil Rights (OCR) at the federal department whose funding the customer receives.
• The captioning standard is consistent. WCAG 2.1 Level AA is the operative standard under all three regimes: EU (via EN 301 549), ADA Title II (via the DOJ's adopted standard), Section 504 (via the same DOJ standard for federally-funded entities). A single per-asset caption-quality file satisfies all three; a single Article 14 assessment is also a defensible disproportionate-burden invocation under the US regimes (which use a "fundamental alteration / undue burden" test that maps closely to Article 14's criteria).

Operating consequence: an EU-and-US SMB writes one statement, files one feedback mechanism, runs one quarterly review, and references the relevant national authorities for each regime in clause 4. The cost of the cross-regime statement is barely higher than the cost of a single-regime statement, and the discoverability gain (one URL for every customer) is real.

Where GlossCap fits — the captioning evidence the statement needs

The accessibility statement is a load-bearing artifact, but it cannot make captions exist. Clauses 1, 6, 7, 11, 12 and 13 all rely on per-asset caption-quality data: which assets have captions, which do not, what the quality scores are against the DCMP threshold, what the retrofit timeline is, what the cost of compliance against the Article 14 assessment is. An SMB that cannot answer those questions per asset cannot write a defensible statement.

GlossCap's product is the per-customer captioning architecture that makes those answers easy to produce. The relevant artifacts:

• Per-asset caption-quality scoring against the DCMP Captioning Key. GlossCap's quality reports produce the per-asset evidence clause 11 needs, scored by the same methodology member-state authorities have flagged as the de facto floor. The reports are exportable as CSV for the clause-2 sampling plan and as a public-facing per-asset detail view for the clause-12 transcript-page index.
• Per-customer compounding glossary. The per-customer glossary architecture means caption quality on the proper-noun categories (drug INNs, procedure terms, ICD-10/CPT, pathogen names, device acronyms, member-state-specific regulation citations) compounds over time and per asset, which is the durable mechanism for hitting the 99% DCMP floor across a 1,000+ asset back-catalogue. See the long-form treatment in our prompting-vs-glossary-vs-fine-tuning post.
• The cost data clause 13 needs. An Article 14 disproportionate-burden assessment needs limb-1 cost data — the cost of bringing the back-catalogue to compliance. GlossCap's Org tier at $299/mo / €280/mo is the per-month figure that goes into the limb-1 numerator. For a 50-employee EU SMB with a 200-asset back-catalogue, the realistic limb-1 figure is €280/mo × 18 months for the full retrofit = €5,040. Set that against limb-1 denominator of the service's annual revenue, and the proportionality test typically resolves the other way — i.e., the requirement is met, the Article 14 invocation is not needed, and the statement claims wholly-conformant on the back-catalogue category by the end of the retrofit window.
• The RFP-template artifact at /seo/captioning-rfp-template for the procurement that flows from the statement-publication exercise. The 14 scoring questions in that template feed the clause-2 vendor-receipt evidence the statement references.

GlossCap is not the only path to a defensible statement; for sub-100-asset catalogues, in-house captioning by a part-time L&D operator can satisfy the requirement on a one-off basis. The product becomes load-bearing once the back-catalogue gets large enough that the per-asset glossary architecture is the only way to hold the 99% floor across thousands of assets without burning a half-FTE per quarter on caption review. The break-even calculation is in the hidden-half-FTE post; the per-tier pricing comparison is in the four-vendor pricing post.

FAQ

Is there a single official EU template I can copy verbatim?

The closest thing to an official template is the Annex to Commission Implementing Decision (EU) 2018/1523, which sets out the 12-clause structure for the public-sector Web Accessibility Directive. It is the same structure that the major EAA member-state transpositions reuse with the two Article 14 / Article 4(5) additions described above. The Commission has not (as of 2026 Q2) published an EAA-specific implementing decision setting out a separate template; the practical answer is to use the 2018/1523 template plus the two add-on clauses, structured per the downloadable template above. Member states have published national-language versions and exemplar statements that are useful starting points — Germany's Bundesfachstelle Barrierefreiheit has the most comprehensive set of exemplar statements and the most detailed clause-by-clause guidance.

Do I need a separate statement per member state, or one statement for all?

One statement that lists each member state's relevant authority in clause 4 and addresses each member state's language requirements in the corresponding language version. Most SMBs publish a single canonical English statement plus translated versions in each of the official languages of each member state of operation. The translated versions are full statements (not summaries), but the substantive content (clauses 1, 6, 7, 13, 14) is the same across all language versions; only clauses 4, 12 and the member-state-specific addenda vary. The Spanish autonomous-community language obligation (Catalan, Galician, Basque, Valencian) is the most aggressive multi-language reading and is worth treating as the upper bound of the obligation.

What happens if I just don't publish a statement?

The statement is one of the explicit Article 13 EAA obligations, and the absence of a statement is itself a finding — independent of any underlying accessibility non-conformance. The MLBF in Germany has been clear that "no statement" is a more serious finding than "statement with documented non-conformances," because the statement is the operator's own representation of the service's accessibility posture and the absence of one prevents the user from making an informed decision. The realistic enforcement path: a complaint lands, the market-surveillance authority requests the statement, the operator either produces it or admits it does not exist. If it does not exist, the authority typically issues a deadline (30 days is common) to publish one and reserves the right to follow up with a substantive review. Operators that publish a statement with documented non-conformances and a credible retrofit timeline are treated more favourably than operators that publish nothing.

How specific does the captioning evidence in clauses 6 and 11 have to be?

Specific enough that a surveyor could reproduce the assessment from the operator's data. The realistic minimum: per-category enumeration in clause 6 (matching the categories above — live, prerecorded-after-cutoff, prerecorded-before-cutoff, marketing video, in-product video, help-center video), with the conformance status and the failing Success Criterion for each category. Clause 11 needs the assessment methodology cited by name (DCMP Captioning Key is the most common reference for caption quality), the sampling plan, and the assessor identity. A statement that says "we assess captions" without naming the methodology or the sampling plan is incomplete. A statement that publishes the per-asset quality scores as a public artifact is over-and-above what most surveyors will require but is the strongest possible defence.

What's the deadline pressure between now and when?

The EAA's substantive obligations have applied since 28 June 2025. The first periodic application reports under Article 30 are due in mid-2027, which means member-state authorities are staffing up for active surveillance through 2026 Q3 and Q4 to populate those reports with substantive findings. The pressure point for an SMB writing its first statement is the run-up to Q3 2026: the German MLBF has indicated that active spot-checks on SMB services will begin in earnest in Q3 2026; the French DGCCRF moved from consultation to active surveillance in Q1 2026; the Italian AgID has been running since the Decreto Legislativo 82/2022 came into force in 2022 and has the longest enforcement track record. The realistic operating timeline for an EU SMB that does not currently have a statement: write and publish within 60 days; lock the catalogue and the Article 14 assessments within 90 days; run the first periodic review at the 90-day or quarterly mark; iterate. The full EAA-EU-SMB walkthrough covers the surrounding timeline in more detail.

What if my service is technically B2B with no consumer surface — am I still in scope?

The pure-B2B-with-procurement-gating reading is contested across member states. The conservative reading is that any consumer-accessible plan (including a free trial that does not require business verification) puts all of the operator's audiovisual surfaces in scope. The non-conservative reading is that pure-B2B services with no consumer-accessible plan are out of scope for the EAA's Article 2 services list, but in scope for the procurement-gating accessibility expectations of any public-sector or large-enterprise customer. Most SMBs that have looked at this carefully decide to write the statement anyway: the cost of writing it is small, the discoverability and trust signal is real, and the EU customers asking the question have started filtering vendors on whether the statement exists. If you have any consumer-accessible surface, treat yourself as in scope; if you are pure B2B, treat the statement as a sales-and-procurement asset.

How does the EAA statement intersect with my existing ADA Title II statement?

One statement covers both. The 12-clause EU template over-satisfies the ADA Title II disclosure expectation, and a single clause-1 reference to both regimes plus a clause-4 reference to both authority sets is the most common cross-regime structure. See the cross-walk section above. The captioning standard (WCAG 2.1 Level AA) is the same under both regimes, so a single per-asset quality file satisfies both. The disproportionate-burden assessment under EAA Article 14 maps closely to the "fundamental alteration / undue burden" test under the ADA Title II rule (28 CFR § 35.164) and a single assessment can do double duty.

The 30-day publication plan

If the statement is currently absent and the operator wants to ship it inside 30 days, the realistic phasing:

• Days 1-7 — scope and inventory. Enumerate the audiovisual surfaces in scope per the categories above. Pull a per-asset list out of the LMS or video host (TalentLMS / Docebo / Absorb / Kaltura / Vimeo / Wistia / Microsoft Stream / Loom / Panopto). Annotate each asset with current caption status (none / autogenerated / human / vendor) and quality estimate. Identify the named role for clause 3 and confirm headcount under Article 4(5) if the carve-out is in play.
• Days 8-14 — sample and score. Sample [N]% of the catalogue per the clause-2 methodology, score against the DCMP Captioning Key, log the per-asset results. Identify the categories in which non-conformance is present and the categories in which retrofit is feasible inside the disproportionate-burden test.
• Days 15-21 — Article 14 assessments and member-state addenda. Write one Article 14 assessment per content category where retrofit is being deferred. Confirm the language obligations and translate the statement into the required national languages. Confirm the autonomous-community contacts (Spain) and the Italian JSON serialisation (Italy). Commission the Leichte Sprache and DGS versions if Germany is in scope.
• Days 22-28 — operationalise the feedback mechanism. Set up the monitored inbox, name the responsible person, write the autoresponder, configure the 7-day acknowledgement reminder. Write the changelog page. Set the calendar reminder for the next periodic review.
• Days 29-30 — publish and announce. Publish the HTML statement at /accessibility, link from the footer of every page, ping IndexNow with the new URL. Send an internal note to the team naming the responsible person and the response-time commitments.

The 30-day plan is feasible for a 50-employee SMB with a 200-asset back-catalogue. Larger catalogues (1,000+ assets) typically extend the sample-and-score phase to 30 days and the assessment phase to 14 days, putting the realistic publication date at 60 days. The retrofit timeline in clause 6 / clause 7 is a separate longer-running workstream that runs in parallel with publication.

Closing — the statement is the start, not the finish

The accessibility statement is a representation, not a magic spell. Publishing one does not make the underlying service accessible; it makes the service's accessibility posture transparent. The value of the statement is in the discipline it imposes on the operator: the per-asset evidence that has to exist for clause 6, the per-category retrofit timeline that has to exist for clause 7, the named role that has to exist for clause 3, the periodic review that has to be on the calendar for clause 10. Each of those is a small operating commitment that, if held, produces a defensible compliance posture across all three regimes (EU, US Title II, Section 504) without further ceremony. Each of them, if not held, surfaces as a finding the next time a market-surveillance authority asks. The template above is the artifact; the operating discipline is the work.

If you want a second pair of eyes on a draft statement, or you want help producing the per-asset caption-quality evidence the statement needs, GlossCap is built for exactly that workflow. Pricing starts at $29/mo for the 50-employee SMB tier. The relevant accompanying reading: the EAA EU SMB Q3 2026 walkthrough, the EAA captions requirements page, the WCAG 2.1 AA captions reference, the SC 1.2.2 prerecorded captions explainer, the 99%-accuracy explainer, the captioning RFP template, the AODA companion regime for Ontario operators, the Section 508 companion for US-federal operators, the Section 504 companion for federally-funded operators, and the LMS-platform reference set across TalentLMS, Docebo, Absorb, Kaltura, Cornerstone OnDemand, HealthStream and Relias. The Joint Commission survey-prep playbook is the parallel artifact for hospital operators in the US; the structural pattern of "load-bearing template + per-asset evidence + named role + periodic review" is identical, just with a different surveyor on the other end of the table.