How to write an accessibility statement for your ecommerce store
An accessibility statement is a public declaration of your site's conformance level, known limitations and contact information for users who need assistance. It serves three purposes: legal documentation, user communication and organizational accountability.
In the EU, the European Accessibility Act requires an accessibility statement for covered entities. In the US, there is no federal requirement for private businesses to publish one, but it is standard practice in ADA lawsuit settlements and it demonstrates good faith. The W3C publishes a template and generator at w3.org/WAI/planning/statements/.
Is an accessibility statement legally required?
For EU ecommerce businesses covered by the European Accessibility Act (EAA): yes, an accessibility statement is required. The EAA, which has applied to new products and services since June 2025 and requires existing services to comply by June 2030 (for services with fewer than 10 employees and under 2M EUR turnover) or June 2025 for larger businesses, explicitly requires an accessibility statement that meets the format defined in the Web Accessibility Directive.
The Web Accessibility Directive (which applies to public sector bodies) provides the template. Private sector businesses under the EAA are expected to follow a similar format. The statement must be in an accessible format, published on the website and kept current.
For US ecommerce businesses under ADA Title III: there is no statute requiring a published accessibility statement. However, having one demonstrates intent and effort. Courts and the DOJ consider good faith in ADA cases. An accessibility statement that acknowledges known gaps and provides a way to request accommodations is evidence of good faith. It does not eliminate liability, but it reduces exposure. For context on the financial implications, see our guide on ADA compliance costs for ecommerce.
The UK, under the Public Sector Bodies Accessibility Regulations, requires statements for public sector. For private ecommerce in the UK, similar logic to the US applies: not required by law, but strongly recommended.
Does publishing an accessibility statement create legal liability?
This is the concern that stops many companies from publishing one. The fear: if we acknowledge known failures, are we admitting liability?
The legal reality is more nuanced. Acknowledging that your site has limitations is not the same as admitting a violation. Courts have generally viewed accessibility statements that disclose limitations and provide contact information positively. A statement that says "We are actively working to improve our checkout flow's keyboard accessibility and expect to complete this by [date]" is evidence of ongoing effort, not admission of wrongdoing.
What creates liability: having no statement, having a statement that is demonstrably false (claiming full conformance with none), or having a statement that provides no contact mechanism for users who need help.
The recommendation from accessibility attorneys: publish a truthful, specific and current statement. The benefit of transparency outweighs the marginal risk of disclosure.
What to include in your accessibility statement
The W3C recommends these components:
- Organization name and scope: the name of the organization publishing the statement and which properties (websites, mobile apps) it covers.
- Conformance status: one of four options: fully conformant (the site fully meets WCAG 2.1 AA), partially conformant (some content does not fully conform), non-conformant (the site does not conform to WCAG), or no assessment (the site has not been evaluated).
- WCAG version and level: specify which version (2.1 or 2.2) and level (A, AA, AAA) you are claiming conformance with or working toward. See our WCAG 2.1 AA checklist for the criteria most relevant to ecommerce.
- Known limitations: a list of known accessibility issues, the affected pages or components, the WCAG criterion that is not met, a description of why it is not currently fixed, and an expected resolution date if known. Be specific.
- Technical specifications: the technologies relied upon for conformance (HTML, CSS, WAI-ARIA, JavaScript) and the compatibility assumptions (tested browsers and assistive technologies).
- Assessment approach: how you assessed accessibility: self-evaluation, automated testing tools used, third-party audit.
- Feedback and contact: a clear mechanism for users to report accessibility issues or request accessible alternatives. Email address and expected response time.
- Enforcement procedure: for EU entities, the supervisory body users can contact if they are not satisfied with your response. Each EU member state has a designated enforcement body.
- Date: when the statement was last reviewed and updated.
A template for ecommerce accessibility statements
The following is a starting template. Customize it to reflect your actual conformance status. Do not claim full conformance unless you have conducted a thorough audit.
"Accessibility Statement for [Store Name]
Last updated: [Month Year]
[Store Name] is committed to ensuring digital accessibility for people with disabilities. We continually improve the user experience for everyone and apply relevant accessibility standards.
Conformance status: We aim to conform to the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA. These guidelines explain how to make web content more accessible to people with disabilities.
Current conformance status: Partially conformant. Some areas of our website do not fully meet the WCAG 2.2 Level AA standard.
Known limitations: [List each known issue. Example: Our product image zoom feature does not currently support keyboard navigation. We are working to fix this by [date]. Our vintage product page archive does not have text alternatives for all images; we are adding these as resources allow.]
Technical specifications: This website relies on HTML5, CSS3, JavaScript and WAI-ARIA. We support the latest two major versions of Chrome, Firefox, Safari and Edge, used with their corresponding platform screen readers.
Feedback: We welcome feedback on the accessibility of our website. If you experience accessibility barriers, please contact us at accessibility@[yourdomain.com]. We aim to respond within 2 business days.
This statement was prepared on [Date]. It was last reviewed on [Date]."
Where to put the accessibility statement
The statement must be easy to find. Standard locations:
- Footer link: the most common placement, labeled "Accessibility" or "Accessibility Statement." This is the first place users and auditors look.
- URL: /accessibility or /accessibility-statement. A predictable URL means users can navigate directly to it.
- Site map: include it in your HTML sitemap and XML sitemap so it is discoverable.
- Contact page: link to it from your contact page, since users with accessibility issues may go there first.
The statement page itself must be accessible. A statement about accessibility that is inaccessible is a failure that is frequently cited in complaints. Ensure the page works with screen readers, has sufficient color contrast and is operable via keyboard.
How often to update your accessibility statement
The statement must reflect your current status. Minimum update frequency: annually. Better practice: update whenever you make significant changes to your site, complete a remediation milestone, or identify new known issues.
Include the date of last review prominently. Auditors checking your statement want to know if it is current. A statement last updated three years ago suggests the organization has not revisited their accessibility status.
After an accessibility audit, update the statement to reflect findings. After resolving known issues listed in the statement, remove or update those entries. The statement is a living document, not a one-time publication.
VPATs and ACRs: how they relate to accessibility statements
A VPAT (Voluntary Product Accessibility Template) is a more detailed document used primarily in B2B contexts, particularly for government procurement. An ACR (Accessibility Conformance Report) is a completed VPAT.
For ecommerce stores selling directly to consumers, a VPAT/ACR is not required. It is used when your product is being evaluated for purchase by an enterprise or government buyer who needs to assess accessibility as part of procurement.
If your ecommerce store sells to enterprise buyers (e.g., corporate gifting, business supply), having an ACR available on request is a competitive differentiator. Government agencies in the US are required to procure accessible technology under Section 508.
An accessibility statement is simpler and sufficient for consumer-facing ecommerce. An ACR provides more granular criterion-by-criterion evaluation and is appropriate when a buyer's legal team requests it.
Examples from major retailers
Target publishes an accessibility statement at target.com/c/accessibility/-/N-4y6ef that acknowledges ongoing improvement efforts and provides a dedicated accessibility contact email. It lists the standards they are targeting and their testing methodology.
Apple's accessibility page goes beyond a statement to describe all assistive technology support in their products, but their legal statement at apple.com/accessibility/website-accessibility-statement/ covers the web property specifically.
ASOS maintains a short accessibility statement that notes their conformance goal, lists known issues and provides a feedback form. The brevity is appropriate: specificity and honesty matter more than length.
Common mistake across major retailer statements: claiming "fully conformant" when automated scans reveal dozens of failures. Use accessibility testing tools to verify your actual status before making claims. This is the single greatest legal risk of an accessibility statement. Claiming full conformance that does not exist is worse than claiming partial conformance. Plaintiff attorneys scan accessibility statements and then test the site. A mismatch between the claim and reality is a strong argument for willful non-compliance.
Frequently asked questions
- Is an accessibility statement legally required for ecommerce?
- The European Accessibility Act requires an accessibility statement for ecommerce services. In the US, an accessibility statement is not strictly mandated by ADA but is considered evidence of good faith effort and is cited favorably by courts.
- What should an ecommerce accessibility statement include?
- Include the WCAG conformance level you target, known limitations, the date of your last audit, a contact mechanism for reporting barriers and your commitment to ongoing improvement. Be honest about known issues.
- Does an accessibility statement protect against ADA lawsuits?
- An accessibility statement alone does not prevent lawsuits. However, a genuine statement with a feedback mechanism and documented remediation timeline demonstrates good faith, which courts consider as a mitigating factor.
Before publishing your accessibility statement, know what is actually on your site. Run our compliance audit checklist first. Complyko scans your checkout, cart and account flows and gives you the violation list you need to write an honest, legally sound statement.
Get your free scan →