Grounded

Public Sector WordPress Accessibility: Building the EU 2018/1523 Document

If you manage a WordPress website for a public sector body in the European Union, the legal requirements for web accessibility are significantly stricter than for standard commercial sites.

Directive (EU) 2016/2102 requires your site to meet accessibility requirements and to publish a detailed accessibility statement, following the model set by Implementing Decision (EU) 2018/1523. The technical level is not named in the directive itself: it arrives through the harmonised standard EN 301 549, and the version whose reference stands published in the Official Journal, V3.2.1, maps to WCAG 2.1 Level AA. The revision aligned with WCAG 2.2 is V4.1.1, expected to be cited around October 2026. Build to 2.2 where you can; claim the level of the standard you are actually measured against.

In this post, we'll explain how our tool helps you audit your WordPress site and automatically generate this mandatory documentation without conflating it with private-sector regulations.

The Confusion: EAA Annex V vs. EU 2018/1523

One of the biggest issues public sector webmasters face is finding the right tool. Most accessibility plugins are geared toward private e-commerce and generate documentation based on the European Accessibility Act (EAA), specifically Annex V of Directive (EU) 2019/882.

Public sector bodies need a different document.

Publishing an Annex V statement on a public sector site means publishing the wrong document — it is not the model Article 7 of Directive 2016/2102 asks for. Our Accessibility Audit plugin distinguishes between the two: configure it for a public sector body and it builds the 2018/1523 model instead. That gets the format right, which is a precondition and not a conclusion. Whether you are compliant depends on the state of your site and on your national transposition, not on which template you published. Several member states also require the statement to go through the competent authority's own portal, and a page on your site does not replace that.

Auditing Your Rendered Pages

Before you can publish your accessibility statement, you need to know where your site stands. Our plugin runs directly inside your WordPress wp-admin dashboard and tests your published pages.

Because it loads the pages in a frame, it tests the rendered result (what the citizen actually sees), rather than the raw HTML sent by the server. This is critical for accurately measuring color contrast over translucent backgrounds or inherited CSS—areas where traditional API scanners constantly fail.

Honest Automation

We believe in full transparency regarding the limits of automated accessibility tools.

Our plugin runs 25 automated checks:

What automation doesn't do: Automated testing finds roughly a third of real accessibility barriers. A clean report from our tool is a fantastic start and necessary for generating your EU 2018/1523 document, but it is not a complete conformance statement on its own. You must still conduct manual testing with a keyboard and screen reader. (Publishing a page via our plugin is also not an official legal filing, and this post is not legal advice).

Generate the Right Document

Stop guessing with generic tools that produce the wrong document. Audit your site and draft the Implementing Decision (EU) 2018/1523 statement in less than two minutes.

Get Accessibility Audit on WPBay

FAQ

Do I need the licensed version to generate the public sector document? Yes. The free version allows you to run 20 checks on up to five pages per scan and provides a full report. However, the document generator (which builds the EU 2018/1523 model) and the ability to scan unlimited pages require a licensed copy.

Does the plugin scan my site automatically every day? No. The scans are run on demand inside your wp-admin area. We do not use continuous external API scanning, which means no performance hits on your front-end and no data privacy concerns regarding external servers analyzing your content.

Can I use this for a private e-commerce site? Yes. If you run a private business or WooCommerce store, simply configure the plugin accordingly. It will instead generate the EAA Annex V document required for the private sector. (Read our WooCommerce EAA guide for more details).

Sources: Directive (EU) 2016/2102 · Implementing Decision (EU) 2018/1523 · EN 301 549 V3.2.1

I am a developer, not a lawyer, and none of this is legal advice. Whether these rules apply to you, and how, depends on your national transposition.