Beyond the Boilerplate: Writing an Accessibility Statement That Actually Helps

Accessibility statements occupy an awkward position in UK digital publishing. They are compulsory, they sit in the footer of every page, and their primary readership consists of people who have just hit a barrier and want to know whether the problem is fixable. All too often, what they find is a page of reassurance addressed to nobody in particular.

That mismatch is worth correcting, because a well-written statement is one of the few accessibility artefacts that delivers value without any further engineering work. It costs a few hours and it pays back in reduced support enquiries, fewer complaints escalating to the regulator and — the part that rarely makes it into the business case — a disabled user who manages to complete the task anyway.

What the regulations actually require

Under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018, a covered body must publish an accessibility statement in an accessible format. Three obligations follow from that duty.

The statement must explain how accessible the website or app is. It must tell people what to do if they encounter content they cannot use, and give them a contact route for reporting it. And it must describe the enforcement procedure available if they are dissatisfied with the response.

None of that is about legal protection. It is about giving a user enough information to make a decision: try another channel, request the content in a different format, or escalate. Read that way, the statement is a service rather than a shield.

The regulations also permit a claim of disproportionate burden for particular content, but the exemption is narrow and must be argued explicitly, with the reasoning published. Asserting it silently, or leaving the justification out altogether, is one of the more common ways organisations find themselves on the wrong side of a monitoring review.

Dates are the first thing readers check

An undated statement is indistinguishable from one written in 2019 and forgotten. The model statement maintained by the Government Digital Service asks for two dates: when the statement was prepared or last reviewed, and when the site was last tested. They serve different purposes and should never be conflated.

“Last reviewed” means a person looked at the statement, checked the claims against the current site and signed it off. “Last tested” means someone actually evaluated the thing — ideally a combination of automated tooling and manual checks with assistive technology. A statement that was reviewed last month but tested three years ago is telling the reader something useful, even if it is not what the organisation hoped.

State the method as well. Naming WCAG 2.2 at level AA as the conformance target, and saying whether testing was internal or commissioned, is more credible than the word “compliant” standing alone. Plenty of organisations cannot honestly claim full conformance, and the regulations do not require them to pretend otherwise.

Known barriers, described in plain English

The section most often left empty is the one users need most. If your date picker cannot be operated by keyboard, if PDFs published before a certain date have not been remediated, if a third-party booking widget fails at the payment stage, say so — and say what the alternative is.

“Some of our content is not fully accessible” is not a known barrier. It is a hedge. A known barrier reads like this: “Our council tax portal uses a date selector that cannot be operated using a keyboard alone. If you need to complete the form without a mouse, call 0xxx xxx xxxx and a member of staff will complete it with you.”

That sentence is uncomfortable to publish and enormously valuable to read. It has a useful side effect, too: writing it forces someone to confirm that the phone line is actually staffed.

A route to a human

The contact requirement is frequently satisfied with a generic enquiries address. That is technically a contact and practically a dead end, because whoever reads it will not know what to do with a report about focus order on page four of a planning application.

Name a route that reaches someone with the authority to act, give a response expectation and explain what happens if the first contact does not resolve matters. Where the organisation offers a feedback form, check that the form itself works with a screen reader. A contact route that is inaccessible is a particular kind of embarrassment.

Enforcement, stated honestly

For public sector bodies in England, Wales and Scotland, enforcement runs through the Equality and Human Rights Commission; in Northern Ireland it is the Equality Commission. The statement should say this plainly, name the relevant body and explain that a user can escalate after contacting the organisation directly.

Some organisations omit this section on the grounds that it invites complaints. It does. It also signals that the duty is taken seriously, which is a better look than silence.

A working skeleton

A statement that does the job typically runs to a few hundred words and covers the following: who the organisation is and the scope of the site or app; the conformance standard targeted and the testing method used; the date of preparation, the date of last review and the date of last testing; a short, specific list of known barriers with the alternative arrangement for each; the contact route, with a named channel and an expected response time; the enforcement procedure; and, where relevant, the disproportionate burden argument with its reasoning set out.

Publish it as an HTML page, link it from the footer of every page and make sure it can be reached from the homepage without a search. A PDF statement is a statement that has failed its own subject matter.

Review it like a service, not a document

Statements rot quickly. A redesign, a new third-party widget or a change of content management system can invalidate half the claims in a fortnight. The practical fix is to tie the review to something that already happens — the annual monitoring return, the accessibility audit cycle or the release that changes the public-facing templates — and to give a named owner responsibility for the page.

The test of a good statement is simple. Hand it to someone who has just failed to complete a task on your site. If it tells them why, what to do next and whom to contact, it is doing its job. If it tells them the organisation is committed to inclusion and leaves it there, it is a disclaimer wearing a statement's clothes.