A graphic featuring a map of Europe in dark blue with a lighter blue figure in a circle at the centre, symbolising accessibility. The circle is surrounded by a ring of twelve yellow stars, representing the European Union, against a deep blue background.

If your organisation runs a UK public sector website or mobile app, you are required to publish an accessibility statement under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. Here is what a valid one actually contains, the common ways teams get it wrong, and what genuine scrutiny looks like.

What the regulations require

The regulations require public sector bodies to:

  1. Meet WCAG 2.1 AA or document which criteria you do not meet and why
  2. Publish an accessibility statement that is accurate, up to date, and meets a defined list of requirements
  3. Review and update the statement at least annually
  4. Respond to feedback from users who report accessibility barriers

The EHRC (Equality and Human Rights Commission) is the designated enforcement body in England, Wales, and Scotland. The Equality Commission Northern Ireland covers Northern Ireland.

What an accessibility statement must include

An accessibility statement must contain:

  • Whether the website or app is partially compliant, fully compliant, or not compliant with WCAG 2.1 AA
  • A list of non-compliant content with the specific reasons for non-compliance
  • Content that is out of scope (such as third-party content you do not control)
  • A contact method for users to report accessibility problems
  • An enforcement procedure explaining that users can escalate to the EHRC if they are not happy with your response
  • The date the statement was last reviewed

GOV.UK provides a sample accessibility statement template that public sector bodies can adapt.

Common accessibility statement mistakes

Copying a template without doing a real audit. The most common failure. An accessibility statement should reflect a tested product, not a hoped-for position. Enforcement bodies and disabled users can tell the difference.

Claiming full WCAG 2.1 AA compliance without evidence. Full compliance is unusual and requires documented testing. Claiming it without an audit is a legal exposure, not a defence.

Out-of-date statement with no evidence of review. Statements must be reviewed regularly. A statement dated 2021 on a product that has changed significantly since then is not compliant.

Missing or broken contact mechanism. Users must be able to contact you to report barriers. A contact form that does not work, or an email address that generates no reply, does not meet the requirement.

Vague non-compliance descriptions. “Some content may not fully meet accessibility standards” is not acceptable. Each known failure should be listed with the specific WCAG criterion it fails.

Private sector and the European Accessibility Act

The accessibility statement requirement currently applies to public sector bodies. However, the European Accessibility Act (EAA) will require consumer-facing businesses in scope to document their accessibility conformance position for EU-facing products and services from June 2025.

If you are a private sector organisation with EU customers, preparing an EAA-aligned conformance document now is good preparation.

I can review or write an accessibility statement for your organisation based on a real audit of your product. Get in touch.