Accessibility statement vs EU EAA for UK firms selling to the EU

Last checked: October 2026. This article compares the UK public-sector accessibility rules with the EU European Accessibility Act (EAA), Directive (EU) 2019/882. It is general information, not legal advice. We quote the directive from the copy on legislation.gov.uk, which shows the text as adopted by the EU; national laws in each member state add their own details.

UK firms often meet the phrase in two places. In the UK, the formal duty to publish an accessibility statement sits in the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018; regulation 8 is headed “Accessibility statement”. GOV.UK says public sector websites must meet WCAG 2.2 AA, publish a statement and review and update it regularly. The duty is aimed at public sector bodies. According to GOV.UK, non-government organisations like charities are exempt unless they are mostly financed by public funding, provide services essential to the public or are aimed at disabled people.

The EAA is a different instrument with a different purpose. It sets accessibility requirements for certain products and services provided to consumers in the EU, and a private business can fall under it even though the UK public-sector rules never apply to it.

A UK private business is not subject to the public-sector statement duty. GOV.UK states that all UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010 or the Disability Discrimination Act 1995 (in Northern Ireland). Its example is giving someone the information they need in another, more accessible format, such as large print or audio. Publishing a statement is not a legal requirement for a private firm in the UK, but it is a sensible way to explain what you have done and how users can ask for help.

The GOV.UK model statement is written for public bodies, yet its structure works for any site. It has these parts:

• Compliance status: fully, partially or not compliant with WCAG 2.2 AA.
• Non-accessible content: what fails, described in non-technical terms, with accessible alternatives where appropriate.
• Preparation: the date the statement was prepared, the method used (self-assessment or third-party assessment) and the date of the last review.
• Feedback and contact information: how users report problems or request content in another form.
• Enforcement procedure: for public bodies, a reference to the EHRC and the Equality Advisory and Support Service.

The model also says the link to the statement should be easy to find, for example in a static header or footer, and recommends reviewing the claims at least once per year. A private firm can leave out the public-sector enforcement wording, which only makes sense for bodies covered by the 2018 regulations.

The directive applies to listed services provided to consumers after 28 June 2025, and e-commerce services are on that list (Article 2(2)(f)), alongside consumer banking, e-books and others. The European Commission lists e-commerce among the covered services as well. Article 3 defines e-commerce services as services provided at a distance, through websites and mobile device-based services, at the individual request of a consumer with a view to concluding a consumer contract.

The point for UK firms is the definition of “service provider” in Article 3: any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union. The directive does not limit this to businesses established in the EU. In our reading, a UK shop that offers sales to EU consumers is therefore inside the definition; how each member state enforces that against a non-EU seller is a question for its national law.

• Selling goods or services to EU consumers through your website: e-commerce services are in scope.
• Only B2B customers: the services listed in Article 2(2) are those provided to consumers, and a consumer is someone acting outside their trade, business, craft or profession. Purely B2B sales are therefore outside this part, but check how your shop handles private buyers.
• Micro-enterprises: Article 4(5) exempts microenterprises providing services from the service accessibility requirements and the related obligations. Article 3 defines a microenterprise as employing fewer than 10 persons with an annual turnover or annual balance sheet total not exceeding EUR 2 million. Products are treated differently; we have not covered them.

Member states had to apply their national measures from 28 June 2025 (Article 31). Those laws name the enforcement authorities and may add details. We did not read them and cannot say what each country requires of a UK business.

Article 13(2) requires service providers to prepare information in accordance with Annex V and explain how their services meet the accessibility requirements. That information must be made available to the public in written and oral format, including in a way that is accessible to persons with disabilities, and kept for as long as the service is in operation. Annex V adds that it belongs in the general terms and conditions, or an equivalent document, and should include, where applicable:

• a general description of the service in accessible formats;
• descriptions and explanations needed to understand how the service operates;
• a description of how the relevant accessibility requirements in Annex I are met.

The combined approach most UK sellers will want is: put the Annex V information where the EAA says it belongs, and also publish a short statement page that links to it. A statement alone may not satisfy Annex V, and Annex V information alone may not be enough to help a visitor. We did not find authoritative guidance that tells UK private firms exactly how to combine them, so treat this as a practical suggestion.

Publishing the information once is not the end. Under Article 13, service providers must have procedures so the service stays in conformity, must take corrective measures if it does not conform, and must immediately inform the competent national authorities of the member states where the service is provided about the non-compliance and the corrective measures taken. On a reasoned request, they must give an authority the information needed to show conformity.

Article 14 lets a business rely on a disproportionate burden or a fundamental alteration of the service, but only after its own assessment, using the criteria in Annex VI. The assessment must be documented and the results kept for five years after the service was last provided. Service providers relying on the burden ground must renew the assessment when the service changes, when an authority asks, and in any event at least every five years. A business that receives outside funding for the purpose of improving accessibility cannot rely on it.

Article 32 also contains a transitional rule: service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date.

1. List the EU countries you sell to and whether you sell to consumers.
2. Check whether you fall under the microenterprise exemption for services (fewer than 10 persons and turnover or balance sheet up to EUR 2 million).
3. Check each country’s national law and enforcement body. We have not.
4. Audit checkout, forms, navigation and PDFs against a recognised standard, and record what you find.
5. Draft the Annex V information for your terms and conditions and make it available in accessible formats.
6. If you rely on disproportionate burden for any part, document the assessment and diarise its renewal.
7. Publish a short accessibility statement page for the website and link it in the header or footer.
8. Offer a contact route and a response time.
9. Review at least once a year and after any redesign.

We build accessible UK and EU-facing sites and can help you describe your site’s features to your legal adviser. We do not provide legal advice or certify compliance. Presentation sites start from €300. See our services and references, request a quote or contact us.

National laws are still being applied and interpreted. Re-check this topic whenever you open a new EU market.

• legislation.gov.uk: Directive (EU) 2019/882 (European Accessibility Act), articles as adopted
• legislation.gov.uk: Directive (EU) 2019/882, Annex V
• European Commission: European Accessibility Act (EAA)
• legislation.gov.uk: Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018
• GOV.UK: Understanding accessibility requirements for public sector bodies
• GOV.UK: Make your website or app accessible and publish an accessibility statement
• GOV.UK: Model accessibility statement