When did anyone last read your accessibility statement?

A statement is the only page that can be used against you

Every other page on a website can have an accessibility defect. The statement is the only one that can have an accessibility claim — and a claim is a different kind of liability. A missing alt attribute is a fault. A published sentence saying the site fully conforms, on a site that does not, is a fault plus a written assertion to the contrary, on your domain, with a date on it.

That asymmetry is why this is worth ten minutes of attention a year. The statement is quoted first in a complaint, opened first in a procurement review, and read first by anybody trying to work out whether you want to hear that something is broken. It is also, on the great majority of sites, the page with the longest gap since anyone looked at it.

The seven elements, and where they come from

Commission Implementing Decision (EU) 2018/1523 sets the model accessibility statement under the EU Web Accessibility Directive. It is the only legally binding list of contents published anywhere, and EN 301 549 — the harmonised standard behind the European Accessibility Act — sits underneath it.

1  compliance status        full / partial / non-compliant
2  the standard applied     a version AND a level
3  non-accessible content   what fails, why, and when it is fixed
4  date                     of preparation, and of last review
5  method of preparation    self-evaluation or third-party audit
6  feedback mechanism       how a person tells you it is broken
7  enforcement procedure    where they go if you do not answer

If you are in the United States, none of that is law: neither the ADA nor Section 508 requires a statement or says what one should contain, and this page will not tell you otherwise. The list is still the right one to be measured against, for a mundane reason — it is the structure every procurement questionnaire borrowed, because it was the only one anybody had written down.

Thirteen sites, read live on 24 September 2026

Run against real sites, the split is not between big and small. It is between the two organisations for whom the list is a legal requirement and everybody else.

gov.uk       /help/accessibility-statement   7 of 7 present   partial, dated 2026-01-29
nhs.uk       /accessibility-statement/       7 of 7 present   partial, 16 months old

shopify.com  /accessibility     no status, no escalation route   nothing links to it
dropbox.com  /accessibility     no status, undated, no route     nothing links to it
basecamp.com /accessibility     no status, undated, no route
slack.com    /accessibility     no status, no standard, undated, no route
bbc.co.uk    /accessibility/    no status, no standard, undated, no route

github.com       no statement found from served HTML
atlassian.com    no statement found from served HTML
mozilla.org      no statement found from served HTML
cloudflare.com   no statement found from served HTML
wikipedia.org    no statement found from served HTML
target.com       no statement found from served HTML

The line to read is the first column of the commercial block. Five of five never state a compliance status — the single sentence saying whether the site conforms, which is the one thing a reviewer opened the page to find. Both public-sector statements do, and the reason is not diligence: the EU Directive makes that sentence mandatory for them and nothing makes it mandatory for anyone else. The same split holds for the enforcement route, present in both and absent in all five.

Two of the commercial statements — Shopify’s and Dropbox’s — were reached by guessing /accessibility, because the served HTML of their homepage carries no link to them. The six “not found” results mean exactly what they say and no more: no accessibility link in the markup the server sent, and nothing at the conventional addresses. A footer drawn by JavaScript produces that result, and so does a statement filed at an unusual path — and so does a regulator’s monitoring crawler, which does what this did.

Everything this checker reports

Six things it counts as missing, eight it reports without counting against you, and one branch for a site where no statement could be found at all.

• The statement never says whether the site conforms

  Required element missing

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  Nowhere in the document does it say that the site is fully compliant, partially compliant, or not compliant with the standard it names. This is the first required element of the model statement and it is the only sentence most readers are looking for. A statement that describes a commitment — that accessibility matters to us, that we are working towards it — without ever stating a status is the single most common shape on the web, and it answers nothing: a procurement reviewer cannot tick a box with it, and a complainant reads it as an admission that nobody measured.

  The fix: State it in one sentence, using the Directive's own vocabulary: "This website is partially compliant with WCAG 2.2 Level AA, due to the non-compliances listed below." Partial is the honest answer for nearly every site, and it is a far stronger position than silence — it shows the site was measured.

• No standard and level is named

  Required element missing

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  The document does not name what it is claiming conformance with. "Accessible", "accessibility guidelines" and "industry best practices" are not standards: they cannot be tested against, so a claim made in those words cannot be verified or defended. A conformance claim is only meaningful with a version and a level attached, because Level A, AA and AAA are three very different promises and WCAG 2.0, 2.1 and 2.2 are three different criterion sets.

  The fix: Name it exactly: "WCAG 2.2 Level AA", or "EN 301 549" if a European procurement rule is the reason the statement exists. If the site was tested against WCAG 2.1 AA, say 2.1 — a real older claim is worth more than an aspirational current one.

• There is no way to report a barrier

  Required element missing

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  No email address, telephone number or contact form is offered in the document for telling you that something is inaccessible. This is the required element with the most direct consequence of any on the list: it is the difference between a person who cannot use your checkout sending you a message and a person who cannot use your checkout sending a demand letter, because the letter is what is left when there is no other route. It is also the element a monitoring body checks first, since it is the one that can be verified from outside.

  The fix: Put a monitored address in the statement itself — not a link to a generic contact page three clicks away — and say who reads it and how fast you answer. A dedicated alias such as accessibility@yourdomain is the usual shape.

• The statement is undated

  Required element missing

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  There is no date of preparation or last review anywhere in the document. An accessibility statement is a claim about a site at a point in time, and a site changes every week — so without a date the claim cannot be read at all. An undated statement is also the shape that most often indicates the document was pasted in once and never revisited, which is the inference a reader will draw.

  The fix: Add one line: "This statement was prepared on 3 March 2026 and last reviewed on 14 September 2026." Then put the review in the calendar, because the date is what makes the next reader believe the rest of it.

• No escalation route is given

  Required element missing

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  The document does not say what a person can do if they report a barrier and are not satisfied with the answer. The model statement calls this the enforcement procedure, and in the EU it means naming the national body that handles complaints. Outside the EU there is no such body to name, and the element still does work: a statement that offers a second step — a named person, an ombudsman, a formal complaints process — visibly gives the reader somewhere to go that is not a lawyer.

  The fix: Name the route. In an EU member state, name the national enforcement body and link it. Elsewhere, describe your own escalation: who a complaint goes to if the first reply does not resolve it, and how long that takes.

• Template placeholders were never filled in

  Required element missing

  The published document still contains the generator's fill-in markers — a bracketed organisation name, a curly-brace token, an obvious sample address. This is the worst possible state for a legal-shaped page: it is published, it is indexed, it carries your domain, and it demonstrates on its face that nobody read it before it went live. It is also the easiest thing in this whole report for someone acting against you to screenshot.

  The fix: Read the page end to end and replace every marker. Then search the published HTML for [, {{ and the word example — the markers that survive are always the ones below the fold.

• An accessibility overlay is named as the reason the site conforms

  Not missing — worth reading

  The statement credits a third-party widget or toolbar for the site's accessibility. An overlay cannot produce conformance and cannot be cited as the basis for a claim: it runs after the page loads, it cannot fix source-level defects such as an unlabelled form field, a wrong heading order or a missing text alternative, and it has been the subject of a large share of the accessibility lawsuits filed in the United States — several of them against sites that had one installed. Naming it in the statement makes the vendor's claim your claim.

  The fix: Remove the vendor from the conformance sentence. Say what was actually tested and what was actually fixed in the source. Keep the widget if you want it, but it is not evidence and it should not be standing in for any.

• The statement claims full conformance

  Not missing — worth reading

  The document says the site fully conforms. That is not a defect and it is not reported as one — it is reported because of the position it puts you in. Full conformance means every page meets every criterion at the level named, and a single missing alt attribute on a single page contradicts it in writing, in your own words, on your own domain. Almost no site of any size can hold the claim across a release cycle, which is why the Directive's model statement has a partial-compliance option and why nearly every serious statement uses it.

  The fix: Unless the whole site has been audited page by page and is re-audited on every release, state partial compliance and list what is outstanding. That reads as competence rather than as a claim waiting to be falsified.

• The statement has not been reviewed in over a year

  Not missing — worth reading

  Review cadence — EU Web Accessibility Directive 2016/2102, Article 7

  The most recent date in the document is more than twelve months old. That is not a failure — the Directive asks for periodic review without fixing an interval, and twelve months is the cadence national monitoring bodies publish. What it means in practice is that the claim describes a site that no longer exists, because a year of releases has been shipped against a statement nobody re-read. If the conformance sentence is still accurate, it is accurate by luck.

  The fix: Re-read it, re-check the things it claims, and update the review date even where nothing else changes. A statement reviewed last month and unchanged is a much stronger document than the same words dated two years ago.

• Partial compliance is claimed with nothing listed

  Not missing — worth reading

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  The statement says the site is partially compliant and then does not say which parts. The model statement requires the non-accessible content to be listed with the reason for each — and the reason this matters more than it sounds is that the list is the only part of a statement that proves anybody looked. A partial claim with no list is indistinguishable from a full claim hedged, and it leaves a reader with a disability no way to find out in advance whether the thing they came to do is one of the broken ones.

  The fix: List them plainly: what is not accessible, which criterion it misses, why it has not been fixed yet, and when it will be. Three specific entries beat a paragraph of qualification.

• The standard named has been superseded twice

  Not missing — worth reading

  The document claims conformance with WCAG 2.0, which was published in 2008 and has been superseded by 2.1 in 2018 and 2.2 in 2023. It is not wrong to have tested against it and this is not counted as a failure — but 2.1 added the criteria that cover mobile, zoom and reflow, and 2.2 added focus appearance, target size and accessible authentication. A 2.0 claim in 2026 says the site was last assessed against a standard that predates the phone the reader is holding. Naming WCAG 2.1 is not flagged here: it is the level US Department of Justice Title II rulemaking names and it is current for most readers.

  The fix: Re-test against WCAG 2.2 Level AA and restate. The delta from 2.0 is mostly mobile and focus behaviour, which is where the real defects are anyway.

• It does not say how the site was assessed

  Not missing — worth reading

  Required element — Commission Implementing Decision (EU) 2018/1523, model statement

  The document does not state whether the assessment was a self-evaluation or an independent third-party audit, or what was used to carry it out. The model statement asks for the method of preparation, and the reason is credibility: a self-assessment honestly labelled is respected, and an unlabelled claim is assumed to be an automated scan somebody ran once. This is in the review band rather than counted as a failure because a statement missing only this is still usable to a reader.

  The fix: One sentence: "This statement was prepared on the basis of a self-evaluation carried out on 14 September 2026 using automated testing and manual keyboard and screen-reader review", or name the firm that audited it.

• The feedback route has no promised response time

  Not missing — worth reading

  There is a way to report a barrier and no statement of how quickly it will be answered. The model statement expects feedback to be answered within a reasonable period, and an unbounded route is the one people stop using: the person who wrote to you three weeks ago and heard nothing is the person who escalates. A timeframe also does useful work internally, because it turns the alias into something with an owner.

  The fix: Add the number: "We aim to respond within five working days." Then make it true — a missed promise is worse than none, and this is the sentence a complaint will quote.

• Nothing on the page you gave links to the statement

  Not missing — worth reading

  The statement was found at a conventional address, but no link to it was present in the HTML of the page checked. A statement that exists and is not reachable does the work of a statement for nobody: not for the person looking for a way to report a barrier, not for a procurement reviewer, and not for a monitoring body, all of whom look in the footer first. The Directive expects it to be published in an accessible and findable place, and in practice that means the site footer on every page.

  The fix: Link it from the global footer with plain text — "Accessibility" or "Accessibility statement" — on every page, next to the privacy and terms links where readers already look for it.

• No accessibility statement was found

  Verify by hand

  No statement was linked from the page given, and none was served at the conventional addresses. For a site inside the scope of the European Accessibility Act or the EU Web Accessibility Directive, publishing one is a legal obligation rather than a nicety. In the United States neither the ADA nor Section 508 requires one — and it is still the page a procurement questionnaire asks for by name, and the only place where a person who hits a barrier can find out that you want to hear about it.

  The fix: Write one. It needs the seven elements listed on this page and it does not need to be long — a page of honest partial compliance with a monitored address on it is worth more than anything longer.

Questions

Where does the list of required elements come from?

Commission Implementing Decision (EU) 2018/1523, which sets out the model accessibility statement under the EU Web Accessibility Directive 2016/2102. It is the only published, legally binding list of what a statement has to contain anywhere in the world, and it names seven things: compliance status, the standard applied, non-accessible content and why, the date of preparation or last review, the method used to prepare it, a feedback mechanism, and an enforcement procedure. EN 301 549 — the harmonised standard behind the European Accessibility Act — sits underneath it.

I'm in the United States. Does any of this apply to me?

Not as law, and this page will not pretend otherwise. Neither the ADA nor Section 508 requires you to publish an accessibility statement, and neither specifies what one should say. The Department of Justice's Title II rule is about the website, not about the page describing it. What makes the list worth reading anyway is that it is the same list a procurement questionnaire asks you to fill in and the same list a demand letter works down — because when everyone needed a structure for this, the EU model was the only one anybody had written.

Is claiming full conformance a bad idea?

Usually, and the tool reports it without calling it a defect. Full conformance means every page meets every criterion at the level you named. A single untagged PDF or one missing alt attribute contradicts that sentence in writing, in your own words, on your own domain — which is a materially worse position than the same site with a partial-compliance statement listing three known issues. The Directive's model statement offers partial compliance for exactly this reason, and nearly every serious statement uses it.

You said my site has no statement. It definitely does.

Then it is somewhere this check could not reach. We read the HTML your server sends for the page you gave, follow the accessibility links in it, and try the conventional addresses — /accessibility, /accessibility-statement, /pages/accessibility and /accessibility-policy. Two things defeat that: a footer built entirely in the browser, so no link exists in the served markup, and a statement filed somewhere unconventional such as /legal/a11y. Paste the statement's own URL directly and it will be read. It is worth knowing which of those it was, because a monitoring crawler does exactly what this did.

Does the checker need the exact URL of my statement?

No — give it the homepage. Finding the statement is deliberately part of the check, because that is the task a reviewer, a regulator's monitoring crawler and a person who cannot use your site all face before they can read a word of it. If we reach it by guessing an address rather than by following a link, that is reported: a statement nothing links to is doing the work of a statement for nobody.

Why is a missing feedback address treated as seriously as a missing conformance claim?

Because of what replaces it. The feedback mechanism is the route by which a person who hits a barrier tells you instead of telling someone else, and when it is absent the someone else is a lawyer or a regulator. It is also the element a monitoring body can verify from outside without reading a line of your code, which is why it is checked first in practice. A monitored address in the statement itself — not a link to a general contact page — is the whole fix.

My statement says an accessibility widget makes the site conformant. Is that a problem?

Yes, and it is the one finding here that has cost people money. An overlay runs after the page loads and cannot repair source-level defects — an unlabelled form field, a wrong heading order, a missing text alternative — so it cannot produce conformance and cannot be the basis of a claim. A large share of US accessibility lawsuits have been filed against sites that had one installed. Naming the vendor in your statement makes their marketing claim your legal claim.

How old is too old?

Twelve months, which is the review cadence national monitoring bodies publish rather than a number in the Directive itself — the Directive asks for periodic review without fixing an interval. It is reported as something to read rather than as a failure. What it means in practice is simple: a year of releases has shipped against a document nobody re-read, so if the claim in it is still accurate it is accurate by luck.

Does naming WCAG 2.1 count against me?

No, and this tool will never say it does. WCAG 2.1 Level AA is the standard US Department of Justice Title II rulemaking names, and it is current for the great majority of readers. Only WCAG 2.0 is flagged — it was published in 2008 and has been superseded twice, and it predates every criterion covering mobile, zoom and reflow. Even then it sits in the review band, because having genuinely tested against 2.0 is worth more than an untested claim about 2.2.

Does a complete statement mean my site is accessible?

No, and that gap is the reason this tool exists alongside the scan. Everything here is a check on a DOCUMENT: whether it contains the things it must contain. Whether the sentence inside it is true is a completely different measurement, and it is the one that decides whether the statement protects you or indicts you. A well-formed statement claiming WCAG 2.2 AA on a site that fails forty criteria is a signed admission with a date on it.