Most "EAA accessibility statement" tools build the wrong document

If you have looked for a tool that generates the accessibility statement the
European Accessibility Act requires, you have probably seen a page listing
these headings:

Compliance status · Non-accessible content · Preparation of this statement ·
Feedback and contact information · Enforcement procedure

That is a real document with a real legal basis. It is the model set out in
Commission Implementing Decision (EU) 2018/1523, and it implements
Directive (EU) 2016/2102 — the directive on the accessibility of the
websites and mobile applications of public sector bodies.

If you are a business selling to consumers, it is not your document.

Mine produced it and called it an EAA statement, until a marketplace reviewer
told me otherwise.

What the EAA actually asks for

The European Accessibility Act is Directive (EU) 2019/882, and the
information obligation for services is Annex V. It is short, and it asks
different questions.

The information goes in the general terms and conditions or an equivalent
document, describes the applicable requirements, and covers the design and the
operation of the service. In addition to the consumer information duties of
Directive 2011/83/EU, it contains, where applicable:

(a) a general description of the service in accessible formats;

(b) descriptions and explanations necessary for the understanding of the
operation of the service;

(c) a description of how the relevant accessibility requirements set out
in Annex I are met by the service.

And then point 3, which is the one nearly everyone drops:

The service provider shall provide information demonstrating that the service
delivery process and its monitoring ensure compliance.

Read those next to the public sector headings and the mismatch is obvious.
2018/1523 asks how conformant are you and what is broken. Annex V asks what
is your service, how does it work, how does it meet the requirements, and how do
you keep it that way.

A scan can help with one section of the first document. It cannot write any of
the second on your behalf, because three of those four points describe a service
that no scanner can see.

Two provisions worth knowing before you publish anything

You may not owe this at all

Article 4(5): microenterprises providing services are exempt from the
accessibility requirements for services, and from the obligations relating to
compliance with them. A microenterprise is fewer than 10 persons and an
annual turnover or balance sheet total not above €2 million.

That is a lot of the people currently being sold compliance tooling.

The exemption is from the obligation, not from your users — accessibility is
still worth doing, and the commercial argument for it does not depend on a
directive. But if you are exempt and you publish a document asserting conformity
with requirements you do not carry, you have taken on an exposure that the law
had spared you.

My generator asks. Tick the box and it stops asserting conformity, cites the
article, and says the information is published voluntarily.

"Disproportionate burden" is not a checkbox

Article 14 lets you claim that meeting a requirement would fundamentally
alter the service or impose a disproportionate burden. What it asks in return:
the assessment must be documented, kept for five years from the last
time the service was provided, redone when the service changes, on request from
an authority, and at least every five years — and you must notify the
relevant market surveillance or service compliance authority that you are
relying on it. That last duty does not apply to microenterprises.

Invoking disproportionate burden with no assessment behind it is the weakest
position available: you have publicly named the requirement you are not meeting
and publicly failed to justify it.

The standard you can actually claim

One more thing that surprises people.

Only a harmonised standard cited in the Official Journal carries the
presumption of conformity. That is still EN 301 549 V3.2.1, which references
WCAG 2.1 AA. The revision aligned with WCAG 2.2 is expected to be cited
around October 2026; as I write this in August 2026, it is not.

So a statement claiming WCAG 2.2 AA is claiming something more than the law
asks and something less than the law recognises. Not wrong, and not the
presumption of conformity either. Worth choosing deliberately rather than
picking the bigger number.

What I changed

The generator now asks which regime applies to you before it asks anything else,
and builds the corresponding document. The public sector model is still there,
for the users it was always right for.

The known-barriers section is still prefilled from your latest scan — that is
the part a scanner can genuinely help with, and it is the section everyone
leaves blank. But a success criterion is attached only where the check really
maps to one, which is a separate story about eight rules that cited criteria
that were wrong, obsolete, or unrelated.

And the screen argues with you: full conformity claimed while your own scan
still reports failures, disproportionate burden invoked with no assessment date,
Annex V point 1(a) left empty, a microenterprise being handed a conformity claim
it does not owe.

The caveats that belong on this, and on anything like it

Publishing a page is not a filing. Where your country requires submission
through a national portal on an official form, generating a page does not
replace it.

I am not a lawyer. I am a developer who read the directive because a
reviewer proved I had built the wrong thing. Whether the obligation reaches you,
and in what form, depends on where you operate, what you sell, and how large you
are.

What I am confident about is narrower, and checkable in ten minutes on EUR-Lex:
2018/1523 is the public sector model, the EAA's information obligation for
services is Annex V, and a tool that hands a business the first one is handing
it the wrong document.

Sources: Directive (EU) 2019/882, Annex V,
Implementing Decision (EU) 2018/1523.