Accessibility statement — who needs one and what must it contain?
An accessibility statement is the page where a website reports how accessible it actually is: what works, which deficiencies exist and how visitors can report problems. For public sector bodies it is a legal requirement under the Swedish DOS Act, and since the Accessibility Act took effect in 2025, private actors such as e-commerce businesses have a corresponding information requirement. Yet the statement is often missing entirely — or says something different from what the website actually delivers.
What does the law say?
The DOS Act — the Swedish Act (2018:1937) on accessibility of digital public services — requires public sector bodies to publish an accessibility statement for their websites and apps. The statement must describe how well the website meets the accessibility requirements (in practice WCAG 2.1 AA), which known deficiencies exist and why, how visitors report deficiencies to you, and include a link to lodge a complaint with the supervisory authority DIGG — the Agency for Digital Government. The statement must also be kept up to date: a statement reflecting the website as it looked three years ago does not serve its purpose.
For private actors covered by the EU's accessibility directive — in Sweden the Accessibility Act (2023:254), in force since 28 June 2025 for e-commerce and banking services among others — there is a corresponding information requirement: they must describe how the service meets the accessibility requirements. Supervision of that act lies mainly with the Swedish Consumer Agency, while DIGG keeps the public sector.
Who is covered?
The DOS Act applies to public sector bodies: government agencies, municipalities, regions and other publicly governed organisations. For them the accessibility statement is mandatory — it must exist, be easy to find (normally linked in the footer) and be current.
Private companies are not covered by the DOS Act. But if you sell to consumers through e-commerce, or offer banking services for example, you are likely covered by the Accessibility Act — and then the information requirement applies: you must describe how the service meets the accessibility requirements. The form differs from the public sector statement, but the core idea is the same — anyone using the service should be able to read how accessible it is.
What must the statement contain?
For public sector bodies the DOS Act spells out the content clearly. The statement must answer four things:
- How well the website meets the requirements — fully compliant, partially compliant or not compliant. "Partially compliant" with honestly reported exceptions is entirely permitted.
- Which known deficiencies exist, and why they are not fixed — for example disproportionate burden or exempted content.
- How visitors report deficiencies to you — a contact route for anyone who runs into problems.
- A link to lodge a complaint with DIGG, for anyone not satisfied with your response.
DIGG provides a template for public sector bodies — you don't need to invent the format yourself. The hard part isn't the structure but the honesty: the statement must reflect the website's actual accessibility, not the ambition.
Common issues we see
- The statement is missing entirely — more common than you'd think, even among organisations that otherwise work seriously with accessibility.
- It is several years old. The website has been rebuilt since, but the statement still describes the old one.
- It claims "fully compliant" or "fully accessible" even though the website has obvious, measurable deficiencies — the claim and reality say different things.
- The complaint link to DIGG is missing, or there is no contact route for visitors who want to report deficiencies.
How CompliantHQ tests this
For public sector bodies, the scanner verifies that an accessibility statement is published and findable at all — as its own page, a footer link or text on the website. We determine whether the statement exists, not whether every part of its content holds up.
Then we do something a document alone cannot: we compare claim against measured reality. If the statement claims full compliance while our accessibility scan finds serious WCAG failures on the same website, we flag the contradiction. It is not a legal assessment of the individual deficiencies — we point out that the statement says one thing and the measurement another, and quote both.
How to fix it
- If the statement is missing: publish one. Start from DIGG's template if you are a public sector body, and link it clearly — the footer is the standard place.
- Be honest about where you stand. "Partially compliant" with a list of known deficiencies is what the law expects from most — an exaggerated claim of full accessibility hurts more than it helps.
- Make sure visitors can report deficiencies to you, and that the complaint link to DIGG is included.
- Keep the statement alive: update it when the website is rebuilt, when deficiencies are fixed and when new ones are found — for example after a scan.
- Private actor covered by the Accessibility Act: describe how the service meets the accessibility requirements, so the information is there for anyone looking for it.
What the check covers
- That public-sector organisations have an accessibility statement — the page where, by law, they report how accessible their site is.
- That an accessibility statement claiming the site is fully accessible isn't contradicted by what our scan actually found.
Common questions
Do private companies need an accessibility statement?
The DOS Act's statement requirement applies only to public sector bodies. But private actors covered by the Accessibility Act (2023:254) — including e-commerce and banking services, since 28 June 2025 — have a corresponding information requirement: they must describe how the service meets the accessibility requirements.
Is there a template for the accessibility statement?
Yes — DIGG provides a template for public sector bodies. It covers what the law requires: compliance level, known deficiencies, a reporting route and the complaint link. The template solves the structure; the content still has to reflect the website's actual accessibility.
Can we state that the website is "fully compliant"?
Only if it's true. The law permits "partially compliant" with known exceptions reported — that is the honest and common level. A claim of full compliance contradicted by measurable WCAG failures is a mismatch between document and reality, and that is exactly what our scan compares.
How often should the statement be updated?
The law requires it to be kept up to date. A good rule of thumb is to review it whenever the website changes significantly and at least once a year — a years-old statement is one of the most common issues we see.
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