Grounded

How to Generate an EAA Annex V Accessibility Statement in WooCommerce

If you run a WooCommerce store serving customers in the European Union, the European Accessibility Act (EAA) — Directive (EU) 2019/882 — has applied since June 28, 2025.

While much of the conversation around the EAA focuses on WCAG conformance, there is a specific documentation requirement that many store owners miss. Annex V asks you to put the information on how the service meets the accessibility requirements in your general terms and conditions, or an equivalent document — and the directive never uses the phrase "accessibility statement" at all. That is the public sector's term, and it comes from a different directive.

However, a generic "we care about accessibility" page is not enough. The law specifies exactly what information must be provided, and getting the format wrong is a common mistake.

(Not sure if the rules apply to your specific business size? Check our guide on the EAA Microenterprise Exemption).

Here is a practical guide on how to generate the correct document for your WooCommerce store without conflating public sector models with private sector requirements.

The Mistake Most Accessibility Tools Make

If you search for an "accessibility statement generator", you will mostly find tools that output a document based on Implementing Decision (EU) 2018/1523.

There is a major problem with this: that model is strictly for public sector bodies (government websites, municipalities, public hospitals) governed by a completely different directive (Directive 2016/2102).

If you are a private business operating an e-commerce service, you owe something else entirely. You are governed by the EAA, and the information you must provide is detailed in Annex V of Directive (EU) 2019/882.

What Annex V Actually Requires

Annex V point 1 says the information shall, where applicable, contain three elements. Point 3 adds a fourth thing to demonstrate:

  1. A general description of the service in accessible formats.
  2. Explanations of how the service operates, including what a consumer needs in order to understand how it works.
  3. How the accessibility requirements in Annex I are met. This is where you explain the technical steps you have taken (e.g., WCAG conformance).
  4. That your delivery process keeps it that way. Annex V point 3 asks separately for information demonstrating that the service delivery process and its monitoring ensure the service stays compliant.

Copy-pasting a template meant for a local council onto your WooCommerce checkout page does not fulfill these requirements.

How to Generate the Correct Document in WordPress

Translating technical accessibility findings into a structured legal statement is difficult. This is why we built a dedicated generator directly into the Accessibility Audit plugin for WordPress.

Instead of generic templates, the licensed edition of the plugin asks whether you are a public sector body or a private service provider. If you select private, it builds the Annex V information for you.

Here is how the workflow operates:

  1. Scan your WooCommerce pages: The plugin loads your published shop, cart, and checkout pages inside a frame in wp-admin and runs 25 automated checks — 18 of them mapped to a WCAG 2.2 success criterion at level A or AA, the other 7 labelled as recommended practice rather than conformance failures.
  2. Generate the draft: The generator uses your latest scan history to prefill the known barriers. It attaches a WCAG success criterion only where a check genuinely maps to one (because honesty about your numbers is critical for a public claim).
  3. Review it and put it where it belongs: The result is drafted as a normal WordPress page you can review and publish. Where you put it matters: Annex V asks for this information in your terms and conditions or an equivalent document, so link it from there rather than treating a footer link as the whole obligation. Publishing a page is not a filing, and where your country requires submission through a national portal, this does not replace that.

Being Honest About the Limits of Automation

It is crucial to understand that no plugin can make you fully compliant with a single click, and publishing a page is not an official legal filing.

Automated scanning tools generally find only about a third of real accessibility barriers. A clean automated report is a great starting point, but manual testing with a keyboard and a screen reader by a real person is still absolutely necessary to guarantee that a disabled user can actually complete a purchase on your store.

Our tool is designed to give you a transparent, structured starting point for your Annex V documentation, saving you hours of administrative work, without making false promises about "automatic legal compliance".

Fix Your Documentation Today

Accessibility requires ongoing human attention, but generating the initial technical documentation shouldn't be a hurdle.

In less than two minutes, you can install the plugin, scan your WooCommerce checkout flow, and generate a draft of your Annex V information. Get the Accessibility Audit plugin on WPBay — then read the draft, correct what it got wrong about your service, and decide with your own advisers what you are willing to put your name to.

Frequently Asked Questions (FAQ)

Does the EAA apply to B2B e-commerce sites?
The EAA primarily targets services provided to consumers (B2C). However, the line between B2B and B2C can blur if your store is technically accessible to the general public. Consulting a legal professional for your specific jurisdiction is highly recommended.

Can I use a free accessibility statement generator instead?
Most free generators are built for the US market (ADA/Section 508) or for EU public sector bodies. Using them for an EU private e-commerce site will result in a document that does not contain the specific information required by Annex V of the EAA.

Does a clean automated scan mean my site is EAA compliant?
No. Automated checks cannot test everything. For example, a scanner can check if an image has an alt tag, but it cannot know if the description actually makes sense to a blind user. Manual testing is always required.

Sources: Directive (EU) 2019/882, Annex V · Directive (EU) 2016/2102

I am a developer, not a lawyer, and none of this is legal advice. Article 4(5) of the EAA exempts microenterprises providing services altogether — read that before you write anything down.