Accessibility statement: mandatory content, feedback and deadlines for reports of barriers

Who must publish an accessibility statement, and where?

Public sector bodies must provide and regularly update a detailed, comprehensive and clear accessibility statement for their websites and mobile applications; Member States ensure that they do (Art. 7(1) Directive (EU) 2016/2102). The model accessibility statement in the Annex to Implementing Decision (EU) 2018/1523 must be used for this purpose (Art. 1). The statement must be provided in an accessible format and, where appropriate, in a machine-readable format (Art. 2). A link to the statement should be placed prominently on the home page or on every web page, for example in a static header or footer (Annex, notes).

Germany

Federal public bodies publish the statement under § 12b(1) BGG. It must be accessible and machine-readable and reachable from the home page and from every page (§ 7(1) BITV 2.0). In addition, the home page must provide an explanation of the main content of the statement in German Sign Language and in Easy Language (Leichte Sprache) (§ 4 no. 3 BITV 2.0). State law for the Länder and municipalities is not covered in this article.

Austria

The WZG applies only to websites and apps of the federal government and of certain bodies financed or controlled by it (§ 2(1) WZG). These bodies publish the statement on the website, reachable at least via the home page (§ 4(2) WZG). The WZG requires the mandatory content laid down by the European Commission and permits optional content (§ 4(1) WZG). For the states (Länder) and municipalities, the state laws apply: § 4(1) StWZG, § 15b(3) Oö. ADG, § 10a(4) Wiener ADG, § 12(5) NÖ ADG 2017, § 59(3) Bgld. GADG, § 76(3) TGADG, § 48(1) K-LGlBG 2022 and § 10a(3) Vorarlberger ADG. All eight state laws reviewed expressly require the model statement adopted under Art. 7 of Directive 2016/2102. According to the FFG, Salzburg transposes the Directive in the Salzburger Teilhabegesetz; that law is not covered here. For a comparison, see the article Accessibility in municipalities: the state laws.

What mandatory content does the model statement require?

The mandatory content is set out in Section 1 of the Annex to Implementing Decision (EU) 2018/1523; Member States ensure that public sector bodies comply with at least this content (Art. 4(1)). In Germany, § 7(4) BITV 2.0 expressly adopts this mandatory content. Section 1 requires:

1. Introduction: name of the public sector body, the websites or apps concerned and the national legislation transposing Directive 2016/2102.
2. Scope of the statement; for mobile applications with version and date (endnote i).
3. Compliance status: fully, partially or not compliant, with reference to the standards, technical specifications or national legislation (endnotes ii to ix).
4. Non-accessible content with the reasons and any accessible alternatives; the section is omitted if it does not apply (endnote x).
5. Preparation of the statement: date of preparation, the method used, for example a self-assessment or an assessment carried out by a third party (Art. 3(1) and (2)), and date of the last review (endnotes xii and xiii).
6. Feedback and contact information: link to and description of the feedback mechanism, and the responsible body or person.
7. Enforcement procedure: link, description and contact details of the competent enforcement body.

Section 2 lists optional content, for example remedial measures with a timeframe, a formal endorsement, a link to an evaluation report or additional telephone support. § 4(1) WZG expressly permits such content. In Germany, federal bodies should where possible state measures that go beyond the minimum requirements and planned measures to remove barriers (§ 7(4) BITV 2.0). There, the statement is based on an actual assessment; it must state whether a third party or the body itself carried out the assessment (§ 7(5) BITV 2.0).

How do you state the compliance status and non-accessible content?

You choose exactly one of three options and delete the others (Annex, endnote ii).

You assign non-accessible content to one of three reasons: non-compliance with the legislation, disproportionate burden under Art. 5 of Directive 2016/2102 (claimed temporarily), or content outside the scope. Describe shortcomings in non-technical terms as far as possible and name the requirement that is not met (endnote xi). In Germany, § 12b(2) no. 1 BGG requires the statement to name the non-accessible parts, the reasons and, where applicable, a reference to accessible alternatives. How an exemption is justified is shown in the article Disproportionate burden.

Practice in Austria: in the 2025 monitoring by the FFG and the federal states, around 8% of the websites and apps checked described themselves in the statements surveyed as fully compliant, 76% as partially compliant and 0.4% as not compliant; 16% gave no information. These figures are self-assessments by the operators. In the in-depth checks of 23 websites in 2025, none was fully compliant; on average, 18 of the 49 WCAG 2.1 level AA criteria tested were not met per website. 52.5% of the statements surveyed invoked disproportionate burden (FFG, Interim Report 2025).

How do you present documents and PDFs in the statement?

Documents are part of the website, so non-accessible documents belong in the statement. The content of websites includes documents and forms for download (Recital 19 Directive 2016/2102); embedded documents are components of websites (§ 2a(1) BITV 2.0). The statement must explain the parts of the content that are not accessible and the reasons (Art. 7(1)(a) Directive 2016/2102). Office file formats are, for example, PDF, Microsoft Office or equivalent open source formats (Recital 26).

Austria

Office files published before 23 September 2018 are exempt unless they are needed for active administrative processes (Art. 1(4)(a) Directive 2016/2102, § 2(3)(a) WZG, for example § 10a(1)(a) Wiener ADG). You list such files in the section “Non-accessible content” under letter c: the content falls outside the scope (Annex, Section 1). Under the WZG, bodies answer requests concerning exempt content within two months (§ 4(3) WZG); in Burgenland the deadline is four weeks (§ 59(3) Bgld. GADG), in Vorarlberg in principle four weeks, extendable by at most four weeks (§ 10a(4) Vorarlberger ADG).

Germany

BITV 2.0 has no cut-off date exemption for office files. For older documents, the only relevant exemption is the one for archives that neither contain content needed for active administrative procedures nor have been updated or revised after 23 September 2019 (§ 2(2) no. 2 BITV 2.0).

For the presentation, a structure by document group works well, for example forms, minutes or reports, each with the shortcoming, the reason and the alternative. Through the feedback mechanism, users can request the information they need, including documents, also for exempt content (Recital 46 Directive 2016/2102). In the 2025 monitoring, several statements invoked disproportionate burden to state that PDF documents could not be published accessibly as standard (FFG, Interim Report 2025). Read more about the obligations for documents in the guide to accessible PDFs. Compliance-Kit remediates documents for accessibility: have your documents made accessible.

Feedback, enforcement and deadlines: who is responsible?

Reports and requests made through the feedback mechanism are answered by the public sector body itself (Art. 7(1) Directive 2016/2102). Enforcement lies with the conciliation body under § 16 BGG for federal bodies in Germany, and in Austria with the FFG for the federal level (§ 5(2) WZG) and with the bodies listed in the table under the state laws for the states and municipalities. The statement must describe and link to the feedback mechanism and contain a link to the enforcement procedure (Art. 7(1)(b) and (c) Directive 2016/2102). Notifications or requests must be answered adequately within a reasonable period (Art. 7(1)); the enforcement procedure is governed by Art. 9(1).

Germany

Federal bodies offer a directly accessible, barrier-free means of electronic contact (§ 12b(2) no. 2 BGG), which should be reachable from every page and easy to use (§ 7(2) BITV 2.0). The statement explains the conciliation procedure under § 16 BGG and links to the conciliation body (Schlichtungsstelle) (§ 12b(2) no. 3 BGG). The conciliation body is located at the office of the Federal Government Commissioner for Matters relating to Persons with Disabilities (§ 16(1) BGG). The application can be made in text form or recorded in person (zur Niederschrift) (§ 16(4) BGG), and the procedure is free of charge for the parties (§ 16(6) BGG).

Austria

For websites and apps under the WZG, the FFG is responsible as long as no ordinance designates another body (§ 5(2) WZG). It receives complaints, examines them and issues recommendations for action where complaints are justified; complaints may only be submitted via an electronic contact option of the competent body (§ 5(1) no. 2 WZG). For bodies of the states and municipalities, the bodies named in the state laws and listed in the table are responsible; § 10a Vorarlberger ADG does not separately name a complaints body. In Vienna, users must first contact the person or body named in the statement before filing a complaint (§ 10a(5) Wiener ADG). 99% of the statements surveyed in 2025 named a feedback contact (FFG, Interim Report 2025).

How often must you update the statement?

In Germany, the statement must be updated annually and after every significant change to the website or app (§ 7(6) BITV 2.0). In Austria, it must be kept up to date (§ 4(1) WZG, § 4(1) StWZG) or updated regularly (for example § 15b(3) Oö. ADG, § 59(3) Bgld. GADG). Implementing Decision 2018/1523 recommends reviewing the statements at least once a year and stating the date of the last review even if the review led to no changes (Recital 3, endnote xiii). After a substantial revision of the website, a new assessment is recommended (endnote xii).

The monitoring shows the largest gap here. In 2025, 64% of the websites and apps checked in the Austrian monitoring had published a statement (2024: 57%). Of these statements, 31% gave a current date and 69% (just under 70%) did not. 73% contained all mandatory content, while 27% lacked mandatory content (FFG, Interim Report 2025). How monitoring bodies carry out their checks is described in the article Accessibility monitoring.

Outline template: how to structure the statement

The following outline follows Section 1 of the Annex to Implementing Decision (EU) 2018/1523. It is a working aid, not legal advice, and does not replace an assessment of your individual case.

1. Accessibility statement: [Name of the body] is committed to making [website/app] accessible in accordance with [WZG, state law, or BGG and BITV 2.0].
2. Scope: [address of the website; for apps, version and date].
3. Compliance status: [exactly one of options a, b or c] with [reference to the standard or legislation].
4. Non-accessible content: a) non-compliance [content, shortcoming, requirement not met]; b) disproportionate burden [content, justification]; c) outside the scope [in Austria, for example, office files published before 23 September 2018]; accessible alternatives.
5. Preparation: prepared on [date], method [self-assessment or assessment by a third party], last reviewed on [date].
6. Feedback and contact: [link to the feedback mechanism, responsible body with contact details].
7. Enforcement procedure: [link and contact: conciliation body under § 16 BGG, FFG or the complaints body of the state].
8. Optional (Section 2): [remedial measures with a timeframe, link to the evaluation report, telephone support].

Federal bodies in Germany add the explanation in German Sign Language and in Easy Language on the home page (§ 4 no. 3 BITV 2.0).