16 September 2026

What 9,000 public-sector statements teach you about your accessibility statement

Since September 2020, Dutch public authorities have been required to publish an accessibility statement for every website, supported by an audit report. On 31 August 2026, the register contained 9,111 websites and apps. Of these, 9.5% fully conform to the standard, 48% partially conform, and 26% do not conform. That is no reason for gloating. It is the most honest dataset available on what a statement requirement does in practice, and it contains three lessons for every online shop covered by the European accessibility law since 28 June 2025.

The figures below come from the public CSV file of the Dashboard DigiToegankelijk, with a reference date of 31 August 2026. The dashboard itself shows slightly different figures one day later, because the register changes every day. This does not affect the proportions.

Where the figures come from

Directive (EU) 2016/2102 requires public sector bodies to provide an accessibility statement for each website and app. In the Netherlands, these statements are collected on toegankelijkheidsverklaring.nl, and Logius reviews them. Each statement is assigned a status from A to E. The applicable dates are set out in Article 12 of the directive: new websites from 23 September 2019, existing websites from 23 September 2020, and apps from 23 June 2021.

This was the position in the register on 31 August 2026, covering 9,111 websites and apps:

• Status A, fully conforms: 870 (9.5%)
• Status B, partially conforms: 4,395 (48.2%)
• Status C, initial measures taken, no audit yet: 543 (6.0%)
• Status D, does not conform: 2,383 (26.2%)
• Status E, no statement: 920 (10.1%)

The interesting part is the development over time. In July 2022, the register contained 3,559 websites and apps, 298 of which had status A: 8.4%. Four years and 5,500 registrations later, that proportion is 9.5%. The number of registrations has more than doubled, while the proportion that fully conforms has barely changed. And this is among organisations that have a legal obligation, a central register, a reviewing body and their own regulator.

If you want to follow the quarterly trend: Digimonitor, an initiative of agency 200 OK, has been tracking these figures since 2020 and publishes an annual monitor on them. What follows is not that analysis. The question is what an online shop, which has only been required to provide a statement since June 2025, can learn from six years of government experience.

Lesson 1: a statement is a process, not a snapshot

Almost half of the register has status B. That is not a failure. For status B, the DigiToegankelijk rules state literally that the website conforms to the law “if measures have been described and there is improvement every year”. The legislator therefore does not expect a site to be finished in one go. It expects a documented route, with a measurable step each year.

The European Accessibility Act essentially requires the same from service providers, only in different words. Annex V to Directive (EU) 2019/882 requires two things: a description of how your service meets the requirements, and information demonstrating that your service delivery process and its monitoring ensure that conformance. Article 13(3) adds procedures that keep your service conformant when the service, the requirements and the standards change.

What the register shows is what happens without that process: a site reaches B and stays there. A statement without a date for the next step describes a snapshot. The law requires both.

Lesson 2: a good exception has six components

Article 7 of Directive (EU) 2016/2102 specifies the minimum information that a public-sector statement must contain about content that is not accessible: which parts are not accessible, the reasons why, and the accessible alternatives that are available. The Dutch register sets its own additional standard, which is printed in every statement with status B: for each individual non-conformance, the cause must be known, the impact must be described, measures must be in place to resolve the non-conformance, and a specific date must be given by which they will have been implemented. The statement for Rijksoverheid.nl lists eleven success criteria that are not yet met, one alternative in the meantime (calling 1400) and one date: 1 January 2028.

The EAA does not prescribe this format. But it is the format that makes a statement verifiable, and that is exactly what the first European court case was about. In the case against Carrefour, in June 2026, the court in Caen used the conformance level stated in the company’s own statement as evidence against it. A statement that says “we are working on it” gives you nothing concrete to rely on. A statement that specifies which criterion, on which page, with what impact, and until when, is a document that you can follow and that others can hold you to.

The six components for each non-conformance, as derived from Article 7 and the register requirement together:

• the success criterion, with its number and level
• a description of what does not work on the page
• the cause: why it was built this way
• the impact: who is affected and what that person cannot do
• the alternative until the issue has been resolved
• the measure and the date for which it is planned

Note the fourth point. A list of technical findings tells a reader nothing; “the order button cannot be reached with a keyboard, so anyone who does not use a mouse cannot complete the purchase” says everything. It is also the sentence that someone without technical knowledge can understand.

Lesson 3: audits expire

The register has strict time limits. An audit report is valid for three years, after which a new audit must be carried out. Status C, a statement without an audit, may exist for only six months, and only if the site is audited or withdrawn within that period.

The EAA does not specify a period in months. Article 13(3) links reassessment to events: a change in your service, in the requirements, or in the harmonised standards. For an online shop that deploys weekly, this is stricter than three years in practice, not more lenient. The practical consequence is the same: include in your statement both the date of the latest assessment and the date or event that will trigger the next one. A statement without an assessment date is a claim without an expiry date.

Two things you should not adopt

The public-sector model is not a template for an online shop, and that is not a minor detail. It addresses a different law.

First, the mandatory feedback mechanism and the standard template come from Article 7 of Directive 2016/2102, which applies to public sector bodies. The EAA does not require a feedback channel anywhere. It is sensible to have one, because someone who encounters a barrier needs somewhere to turn, but do not present it in your statement as a legal obligation that you are fulfilling. What the EAA does require is set out in Annex V, starting with a description of your service and how it works. That section is entirely absent from the public sector template.

Second, the enforcement link. Public sector statements refer to the National Ombudsman, because that is the route provided by Article 9 of that directive. For an online shop, the route is different. In the Netherlands, the ACM is the market surveillance authority for e-commerce under the EAA, and Article 29 of the EAA also gives consumers access to the courts. So do not copy an Ombudsman link, and name the authority that applies to your service.

And do not compare your site with the register. Different law, different researchers, different sample. What you can adopt is the approach: a statement that says what is wrong is worth more than one that conceals it.

What can you do now?

Start by asking whether your current statement passes the three lessons. Does it include a testing date? For each deviation, does it state what the consequence is and when it will be resolved? Does it explain how you keep this information up to date? Three noes are not a disaster, they are a work list.

You can have the part that requires testing assessed. With one honest caveat: automated testing covers part of the standard, never the entire standard. Our scanner tests the criteria that a machine can assess, either partly or fully. The rest requires human assessment, and the public sector reports in the register show what such an assessment looks like: a judgement for each criterion and, for each finding, a page, a cause and a consequence.

Wexlo scans websites for accessibility and is transparent about what automated testing can and cannot detect. This article provides information, not legal advice.