EAA compliance: how to write an Accessibility Statement for your app
The European Accessibility Act (EAA) is EU-wide legislation designed to make digital products and services accessible to everyone, including people with disabilities. If you provide digital products or services through a mobile app, you need processes and documentation that demonstrate how accessibility is managed and maintained. You can do this with an Accessibility Statement.
Accessibility Statement
The EAA requires clear, transparent information about whether a service or product meets the accessibility requirements set out in the Act. This information must be documented in an Accessibility Statement.
An Accessibility Statement serves two purposes. For users, it explains the accessibility features and limitations of the app. This is especially important for people with disabilities, because it allows them to make an informed choice about how to use the service or app. For regulators, it provides evidence of compliance.
The EAA does not provide a fixed template for an Accessibility Statement, but it does set out requirements. The statement must be documented in writing and can be divided into two parts: one part publicly available for users, and another part with detailed information available on request by the competent authorities. Article 13 and Annex V of the EAA describe what an Accessibility Statement should cover.
What to include in the public part (for users)
General description of the service or app
Accessibility of the service or app:
list the assistive technologies that can be used with the app (for example, the app works with large text, has sufficient contrast, etc.)
include specific accessibility features available in the app (for example, high contrast mode in the app settings)
inform users about accessibility limitations (for example, “Screen A, B, C do not work with an external keyboard”)
mention any special accessibility cases (for example, in older Flutter apps, full keyboard access must be switched off to navigate the app with an external keyboard)
describe measures for non-accessible parts (limitations, alternatives)
Contact information for reporting accessibility problems
Date of the statement and updates
What to include in the internal part (available on request)
Conformity assessment method (self-assessment, external audit, user testing, etc.)
Detailed test results (evidence of compliance, unresolved issues, remediation plans)
Governance and processes (how accessibility is embedded in the organisation, supplier agreements, HR processes)
Supporting documentation (technical documentation, certificates, contracts)
How and where to publish
The EAA allows you to include the public part of the Accessibility Statement in your Terms and Conditions or an equivalent document. Best practice is to publish a dedicated accessibility page on your website and in your app, ideally shown to users right after installation. You can also link to it from your Terms and Conditions and add it as a separate section in the app.
For the non-public parts, keep everything in writing, accurate, and up to date, so you can provide it if the authority requests it.
You may also choose to publish all information in one place. If so, start with a short summary for users and place detailed material in an annex to keep the page clear and readable.
Do not forget who you are doing this for
The Accessibility Statement is not just a compliance document. It is aimed at your users on the one side, and regulators on the other. For users it is extremely important to understand how they can use your app in the best way.
Is there a high contrast mode available? Say it. Do you support larger text, captions, transcripts or screen reader navigation? Mention it. If there are limitations, be open about them and explain your plan. Use plain language and keep the page simple so people can make the most of all features.
For the compliance part, remember that this is not about producing a document once. It is about recording your current state and progress, and using that process to continually improve the accessibility of your products and services.