Accessibility Statements: Legal Requirements in 2026

Accessibility Statements: Legal Requirements in 2026

If you run a website for a public sector organization, university, or even a larger private company serving the public in Europe, you’ve probably heard about accessibility statements. But what exactly do they need to contain in 2026, and who really needs to have one? The rules have evolved quite a bit since the initial EU directive rolled out, and ignoring them can lead to serious compliance issues and potential fines.

I remember when I first encountered this requirement back in 2020 while working on a municipal website project. We thought slapping a basic statement on a page would be enough. It wasn’t. An audit caught multiple deficiencies, and we had to scramble to fix everything properly. That experience taught me that accessibility statements aren’t just legal checkboxes—they’re genuine commitments that require ongoing attention.

Who Actually Needs an Accessibility Statement?

The legal landscape in 2026 is clearer than ever before. Under the EU Web Accessibility Directive (2016/2102) and its various national implementations, all public sector websites and mobile applications must have an accessibility statement. This includes government agencies, municipalities, public universities, hospitals, libraries, and any organization funded primarily by public money.

In many countries, the requirement has expanded beyond just public sector. For example, the European Accessibility Act, which came into full effect in June 2025, extends accessibility obligations to private companies providing certain services like banking, e-commerce, and transportation. If you fall into these categories, you need a statement even if you’re a private business.

The key question: Does your organization serve the public and receive public funding, or do you provide essential services? If yes, you almost certainly need an accessibility statement in 2026.

What Must Be Included in Your Statement

A proper accessibility statement isn’t just a paragraph saying ”we care about accessibility.” The law requires specific elements, and missing even one can put you in violation.

First, you need a compliance status declaration. You must honestly state whether your website is fully compliant, partially compliant, or not compliant with WCAG 2.1 Level AA standards (which is the legal baseline in most EU countries). Don’t be tempted to overstate your compliance—auditors will check, and false claims create bigger problems than admitting shortcomings.

Second, list any non-accessible content. If certain pages or features don’t meet accessibility standards, you must identify them specifically. This might include PDFs that aren’t properly tagged, videos without captions, or interactive elements that don’t work with screen readers. For each issue, explain whether it’s a disproportionate burden to fix (more on that later) or if you’re planning to address it with a specific timeline.

Third, provide a feedback mechanism. Users need a clear way to report accessibility problems or request information in alternative formats. This typically means an email address, phone number, or contact form dedicated to accessibility issues. You must also commit to responding within a reasonable timeframe—many countries specify 15 to 30 working days.

Fourth, include enforcement procedure information. If someone isn’t satisfied with your response to their accessibility complaint, they need to know where to escalate the issue. In most EU countries, this means providing contact details for the national enforcement body responsible for monitoring web accessibility.

The Disproportionate Burden Exception—Use It Carefully

One aspect that confuses many website owners is the ”disproportionate burden” clause. This legal provision allows organizations to claim that certain accessibility improvements would impose an unreasonable financial or organizational burden relative to the benefits provided.

However, this isn’t a blanket excuse to ignore accessibility. To legitimately claim disproportionate burden, you need to document a proper assessment considering factors like the size of your organization, estimated costs, frequency of use of the problematic content, and available resources. You can’t just say ”it’s too expensive” without backing it up.

From what I’ve seen, small municipalities sometimes successfully invoke this for extensive archive content that sees minimal use. But for main navigation, frequently accessed information, or essential services, the disproportionate burden claim rarely holds up.

Technical Requirements and Format

Your accessibility statement must be provided in an accessible format itself—which seems obvious but is frequently overlooked. Use clear, plain language without excessive jargon. Structure the content with proper headings, and ensure it works well with assistive technologies.

The statement should be easily findable, typically linked from every page footer. Many countries require it to be accessible within a maximum of three clicks from any page. The URL often follows a standard pattern like ”yoursite.com/accessibility” or ”yoursite.com/tillganglighet” in Swedish-speaking regions.

Mobile Applications Need Statements Too

If your organization offers a mobile app, it needs its own accessibility statement. This covers both iOS and Android versions. The statement should be easily accessible from within the app, usually in the settings or help section.

Mobile app accessibility statements follow similar content requirements as website statements but should address mobile-specific considerations like gesture controls, screen orientation, and compatibility with mobile screen readers like VoiceOver and TalkBack.

Keeping Your Statement Updated

Here’s where many organizations fall short: accessibility statements aren’t one-time documents. Whenever you make significant changes to your website, update content, or modify functionality, you should review whether your accessibility statement needs updating.

Best practice in 2026 is to review and formally revise your statement at least annually, even if nothing major has changed. Include the revision date prominently in the statement itself—auditors specifically look for recent dates as evidence of ongoing compliance efforts.

Common Misconceptions About Accessibility Statements

Myth: Having a statement means you’re automatically compliant. Wrong. The statement documents your current compliance level, including shortcomings. It’s a transparency tool, not a shield against accessibility requirements.

Myth: Only websites with accessibility issues need detailed statements. Even if your site is fully compliant, you still need a statement confirming that status and providing the required contact information.

Myth: Small organizations are exempt. Size doesn’t automatically exempt you. If you’re a public sector body or provide covered services, you need a statement regardless of organization size.

Practical Steps to Create Your Statement

Start by conducting an honest accessibility audit of your website. You can use automated tools like WAVE or Axe DevTools as a starting point, but don’t rely on them exclusively—automated tools catch only about 30% of accessibility issues. Consider hiring an accessibility expert for a manual review, especially for complex sites.

Document your findings systematically. Create a spreadsheet listing each accessibility issue, its severity, which pages it affects, and your plan to address it. This becomes the foundation of your statement’s non-compliant content section.

Draft your statement using your national authority’s template if one exists. Many countries provide official templates that ensure you include all required elements. Customize it with your specific compliance status and contact information.

Finally, implement that feedback mechanism properly. Don’t just create an email address that nobody monitors. Assign someone responsibility for responding to accessibility inquiries within your promised timeframe.

What Happens If You Don’t Comply?

Enforcement varies by country, but consequences are real in 2026. Some countries impose direct fines ranging from a few thousand to tens of thousands of euros. Others use enforcement notices requiring fixes within specified deadlines, with penalties for continued non-compliance.

Beyond legal consequences, non-compliance damages your reputation. When users with disabilities can’t access your services and find no way to request help, they share those experiences publicly. In an era of social media and review sites, accessibility failures quickly become PR problems.

More practically, accessible websites simply work better for everyone. Clear navigation helps all users. Good color contrast aids people viewing sites in bright sunlight. Keyboard navigation assists anyone with a temporary injury. Accessibility isn’t just legal compliance—it’s good design that expands your audience.

The bottom line: if you need an accessibility statement in 2026, don’t treat it as bureaucratic paperwork. View it as an opportunity to demonstrate your commitment to inclusive digital services, document your genuine efforts to serve all users, and create a clear path for continuous improvement. Do it right, keep it updated, and make sure the contact email actually reaches someone who cares.