Your Accessibility Statement Is a Legal Document. Here's What to Put in It — and What Never to Promise

Somewhere in the footer of your site is a page called “Accessibility”. It was probably written years ago, possibly by a vendor, possibly copied from another agency. It very likely contains a sentence claiming the site is fully accessible, or fully WCAG compliant, or committed to meeting all applicable standards.

If any of that is untrue on the day someone reads it, you have published a written statement contradicting your own site. That is a strange document to have to explain later.

The good news is that an accessibility statement is one of the few compliance artefacts you can get completely right in an afternoon, and an honest one is genuinely safer than a confident one.

Is an accessibility statement actually required?

In the United States, not as a standalone legal mandate. Neither the ADA Title II web rule nor the Revised Section 508 Standards at 36 CFR Part 1194 contains a provision that says “publish an accessibility statement”. The W3C is explicit that conformance claims are optional, and that you may make one only if you have actually tested.

So why does every serious public-sector site have one?

Three reasons, and they are all practical rather than formal. First, GSA treats an accessibility statement as a normal component of a federal agency’s Section 508 programme, and federal practice tends to set the expectation the rest of the public sector is measured against. Second, the statement is where you discharge an obligation that is real: giving people a way to report a barrier and request content in an alternative format. Third, it is the first thing an investigator, a plaintiff’s attorney, or a curious journalist reads — and it is the single page on your site where you get to frame your own compliance posture in your own words.

An entity with a documented plan, a known-issues list and a working feedback channel is in a demonstrably different position from one with silence or one with an unsupported boast. The statement is where that difference becomes visible.

What belongs in the statement?

Six components, in roughly this order.

1. A specific conformance target, named by version and level. “WCAG 2.1 Level AA” — not “accessible”, not “ADA compliant”, which is not a standard and means nothing testable. Name the standard that actually binds you; which one that is depends on whether you are a state or local government entity, a recipient of federal health funding, or a federal agency or its vendor, and Section 508 vs ADA vs WCAG sets out the difference.

2. An honest conformance status. The W3C’s vocabulary gives you four options — fully conformant, partially conformant, non-conformant, or not assessed — and for most public entities mid-programme the truthful answer is partially conformant. Say so. “Partially conformant, with a documented remediation programme” is a defensible position. “Fully conformant” is a claim you must be able to prove for every page and every document on the site, on any day someone checks.

3. A known-issues list, in plain language. This is the part most statements omit and the part that does the most work. Write it the way a resident would understand it: “Videos published before 2024 do not have captions.” “Our permit portal is provided by a third-party vendor and has known keyboard navigation problems; we are working with them and you can complete the same application by phone at [number].” Not “fails SC 1.2.2” — the reader is not holding a copy of WCAG.

Counter-intuitively, disclosure is protective. A documented, acknowledged, scheduled barrier tells a very different story from an undiscovered one.

4. Alternative access routes. For each significant barrier, how does someone get the service anyway? A phone number, an email address, a physical counter, a staffed process. This is the operative content of the page: it converts a barrier into an inconvenience.

5. A feedback mechanism that a human monitors. A named contact, an email address, a phone number, and — critically — a stated response time you can actually meet. Two business days that you honour beats one business day that you do not. If you have a formal ADA grievance procedure or a designated ADA coordinator, link to it here.

6. The date, and the assessment method. When was the statement last reviewed, who assessed the site, and how — automated scanning, manual testing, assistive-technology testing, or some combination. An undated statement reads as abandoned. And the difference between the methods matters more than people assume; automated scan versus manual audit explains what each one can and cannot find.

What must you never promise?

This is the section worth being blunt about, because the language that gets entities into trouble is always aspirational language written by someone in a hurry.

Never claim full conformance you have not tested. Every page, every PDF, every embedded component, verified — or do not say it.

Never guarantee an outcome. No statement should promise that the site is legally compliant, that it will pass an audit, or that it satisfies every applicable law. You do not control how a regulator or a court will characterise your site. Describe what you have done and what you conform to; do not warrant a conclusion that belongs to somebody else.

Never claim a certification that does not exist. There is no government body that certifies a website as accessible. Badges and seals sold by overlay vendors are marketing, not accreditation, and asserting one is worse than saying nothing.

Never promise a fix date you have not resourced. “We will remediate all PDFs by the end of the quarter” is a commitment in writing. If it slips, the statement becomes evidence of a missed commitment rather than evidence of a plan. Prefer “our remediation programme prioritises documents currently used to apply for or participate in services” — true, specific, and not a hostage.

Never imply an overlay solved it. An accessibility widget that changes contrast or font size does not remediate underlying code, and a statement that points to one as the remedy invites exactly the scrutiny you were hoping to avoid.

Does the statement need to be translated?

Yes, and this is the omission we see most often — including on sites that are otherwise doing this well.

Think about who the statement is for. It is for a person who hit a barrier and needs to tell you, or needs the content another way. If that person has limited English proficiency and a disability, an English-only accessibility statement is a barrier guarding the door to the barrier-reporting process. The two obligations compound rather than sit side by side: accessibility under the ADA or Section 508, and language access under Title VI of the Civil Rights Act, which remains the correct authority even though the executive order once cited alongside it has been revoked.

Publish the statement in the languages you publish vital documents in. Mark each version with the correct language attribute so a screen reader pronounces it properly — the mechanics are in translated documents and WCAG language of parts. And make sure the feedback channel actually accepts messages in those languages, because a Spanish-language statement pointing at an English-only inbox is theatre.

A quick self-check

Open your current statement and ask five questions. Does it name a standard and a version? Is its conformance status honest? Does it list real known issues with real workarounds? Is there a monitored contact with a response time you meet? Is it dated within the last twelve months, and does it exist in your other published languages?

If you answer no to two or more, the statement is doing less for you than a blank page would, because it is making claims you cannot support.

Want your accessibility statement reviewed, rewritten, and translated? Send us the URL of your current statement, the standard your programme targets, the results of any assessment you have had done, and the languages you publish vital documents in, then request a quote. We will tell you which sentences are exposing you and what an accurate version says instead. Our ADA website accessibility page covers how we assess a site before a statement is written — because a statement is only as good as the testing behind it.