How to Write an Annex V Declaration

How to Write an Annex V Declaration

"Annex V declaration" is a common name, but the Directive never uses it. What the European Accessibility Act asks of service providers is to publish information on how the service meets the accessibility requirements. Most businesses do that with an accessibility statement page. This guide explains what the law requires, what it does not, and a structure that covers both the law and what users need.

What the law says

Article 13(2) of Directive (EU) 2019/882: service providers prepare the information in accordance with Annex V and explain how their services meet the applicable accessibility requirements. The information must be available to the public in written and oral form, including in a way accessible to persons with disabilities, and kept for as long as the service is in operation.

Annex V, point 1, says the information goes in the general terms and conditions or an equivalent document, and includes:

1. a general description of the service in accessible formats;
2. the descriptions and explanations needed to understand how the service operates;
3. a description of how the service meets the relevant accessibility requirements of Annex I.

Point 2 adds that providers may apply harmonised standards and technical specifications to meet these obligations — in practice, EN 301 549.

That is the whole legal content. There is no required template, no mandatory "compliance status" wording and no filing with an authority.

What it is not

• Not the EU declaration of conformity. Manufacturers of covered products (computers, phones, terminals, e-readers) carry out a conformity assessment, draw up an EU declaration of conformity and affix the CE marking. That paperwork — with model, type and batch numbers — is for products, not for a website's service information.
• Not the public-sector accessibility statement. Public bodies follow a different law, the Web Accessibility Directive, with a model statement set by Commission Implementing Decision (EU) 2018/1523. Its structure is a useful template, but it is not mandatory under the EAA.

A practical structure

This structure covers the three Annex V points and adds what users and authorities look for:

1. The service. What it is, who it is for, which websites, apps and channels the statement covers.
2. How it works. The main steps — finding, choosing, paying, getting support — and the accessibility features available, such as keyboard use, zoom and reflow, captions, and alternative contact channels.
3. How the requirements are met. The standard you test against (EN 301 549 v3.2.1, which uses WCAG 2.1 Level AA), how you tested — automated tools, manual checks, testing with users — and when.
4. Known limitations. Content or features that are not yet accessible, why, the alternative you offer meanwhile and when you expect to fix it. Honest limitations are better than a "fully compliant" claim you cannot prove.
5. Exemptions. Any disproportionate-burden assessment you rely on (Article 14) and what it covers — remember it must be documented and the competent authority informed.
6. Feedback and support. How to report a barrier or request information in an accessible format, and how fast you answer. Include a phone or other oral channel: the Act asks for written and oral availability.
7. Enforcement. The national authority a user can turn to — optional, but helpful and expected in many countries.
8. Date. When the statement was last reviewed.

Where to publish

• As a page linked from the footer of every page and from the terms and conditions — that satisfies "terms and conditions or an equivalent document".
• Linked from places where users need help: checkout, account and contact pages.
• In an accessible format itself: real HTML with headings, not a scanned PDF.
• Available orally on request, for example through customer support.

Keeping it current

Review the statement whenever the service changes in a way that affects accessibility — a new checkout, a new app version, a new third-party widget — and at least once a year. Keep the earlier versions and your test records: if an authority checks the service or follows up a complaint, the statement and the evidence behind it are what it reads first.

Common mistakes

• Copying a generic template that names no service, standard or test date.
• Claiming full compliance on the basis of an automated scan alone.
• Listing known problems with no alternative and no timeline.
• Hiding the page — reachable only through the terms, or published as an image or inaccessible PDF.
• Forgetting the oral channel and the accessible format the law asks for.

Using RankProof's statement generator

RankProof's free accessibility statement generator drafts a statement in any of six languages around Article 13 and Annex V: service description, how it works, the accessibility features offered, the assessment method and dates, compliance status with known issues and a fix date, disproportionate-burden notes, contact channels with a reply time, and the enforcement authority. If you scanned a page with the accessibility scanner first, its findings can be imported as known issues; it never sets "fully compliant" for you. It is a drafting aid, not legal advice — check the result against the law of each country where you offer the service.