Accessibility statements that are missing or say nothing

Fernleaf Tea, a small online shop, asks for a delivery date at checkout. The date is picked from a calendar that opens only on a mouse click and is never read by a screen reader. The shop's own team knows: it came up in their last test, and the fix is planned for the new year.

A keyboard user reaches the calendar and can't open it. They look for help where sites usually put it, at the bottom of the page, and find only the copyright line. Nothing says the calendar is a known problem, that leaving the date empty gets the first available day, or that the shop takes orders by email. They leave with the basket full.

The shop could have done this in a second way that is just as common. Its footer does have an Accessibility link, but the page behind it holds one sentence: "Fernleaf Tea is committed to accessibility. Our website conforms to WCAG 2.1 Level AA." It names no barrier, no other way to order, no contact and no date, and it claims a conformance the calendar breaks.

No WCAG success criterion asks for an accessibility statement, so a site can pass every WCAG check and still fail here. The requirement comes from the procurement standards and the laws built on them:

• EN 301 549 12.1.1 asks that the documentation of a product list its accessibility and compatibility features and explain how to use them, and 12.2.2 asks that its support services give the same information.
• Section 508 602.2 asks the same of support documentation: the built-in accessibility features, and those that work with assistive technology, listed and explained.
• In the EU, public sector bodies must publish a statement in the form the Commission set out in Implementing Decision 2018/1523, and the European Accessibility Act, in force since 28 June 2025, asks the services it covers, online shops among them, to publish how they meet its requirements.

These clauses were written for products and their manuals, and for a website the statement is where that information lives. Both broken pages fail them: the first says nothing at all, and the second describes no feature, no barrier and no support. The second is also worse than silence. A claim of full conformance tells someone who is stuck that the fault must be theirs.

Every site has barriers somewhere, and a statement is the one place that tells people which ones and what to do instead. Without it, each person who meets a barrier finds it alone, and the shop never hears about it.

10 of 10 groups affected

• No vision (affected)
• Low vision (affected)
• Colour vision (affected)
• No hearing (affected)
• Hard of hearing (affected)
• No speech (affected)
• Motor (affected)
• Reach, strength (affected)
• Cognitive (affected)
• Seizures (affected)

• Limited manipulation A keyboard user who can't open the delivery calendar has no way to learn that leaving the date empty works, or that the shop takes orders by email, so the basket is abandoned.
• Without vision A screen reader user who meets the same calendar can't tell whether it is broken or they are doing something wrong, and finds no one to ask.
• Limited vision Someone who zooms in until the checkout scrolls sideways can't learn whether that is known, or how else to order.
• Without hearing A deaf visitor who finds a product video with no captions can't learn whether a transcript exists, and a phone number as the only contact shuts them out.
• Limited hearing Someone who can't follow a video's quiet narration can't find out whether captions are coming, or where to ask for the words.
• Without perception of colour Someone who can't tell which size is chosen, because only colour marks it, finds no page that says so or offers another way to check.
• Without speech Someone who can't speak can't use a phone line, so with no written contact listed anywhere they have no way to report the barrier.
• Limited reach and strength Someone who can't reach or press a control the way the page expects finds no other way to finish the order, and no one to tell.
• Limited language, cognitive and learning abilities A page that only says the site meets WCAG tells someone who is stuck that the problem must be theirs, and gives them nothing to do next.
• Photosensitive seizures Someone who must avoid flashing content can't learn beforehand whether any page has it, because nothing says what was checked.

Because no WCAG rule asks for a statement, page checkers such as axe never mention one. This audit looks across all the pages it was given for a link to a statement: a link named Accessibility, Accessibility statement or a similar name in English or Japanese, or one whose address has "accessibility" in it. When none of the pages has one, it sends a review lead rather than a finding, since the statement may be linked from a page the audit was not given, or sit in a help page that the footer links as Help. It can't judge what a statement says: whether the barriers listed are the real ones, whether the claim matches the tests, or whether anyone answers the email.

AI tools and statement generators write a tidy page in seconds, and that is the risk. Asked for "an accessibility statement", they write the commitment and the WCAG claim, because those are the parts that need no facts. The parts that help someone who is stuck, the known barriers, the other ways round them and a contact who answers, can only come from testing the site and from the people who will answer.