How to Write an Annex V Declaration

How to Write an Annex V Declaration

Article 13(2) of the European Accessibility Act requires service providers to publicly document how their services meet the accessibility requirements of Annex I. This document — the Annex V declaration — is your legally mandated accessibility statement.

What is an Annex V Declaration?

The Annex V declaration (sometimes called an "accessibility passport" or "EU accessibility declaration") is a formal document that:

1. Identifies your organisation and the service covered
2. States which accessibility standards you follow
3. Documents how your service meets each applicable Annex I requirement
4. Acknowledges any areas of non-compliance or claimed exemptions

It is not the same as a WCAG conformance statement (though it may reference one). The Annex V declaration specifically addresses the legal requirements of the EAA, not just technical WCAG criteria.

Mandatory fields

The EAA specifies that the declaration must include:

1. Provider identification (V.1.a)

• Full legal name of the economic operator
• Registered business address
• Contact information for accessibility inquiries

2. Product/service identification (V.1.b)

• Clear description of the product or service
• Version number (for software/web services)
• Scope (which URLs, platforms, or product models)
• Date of the assessment

3. Standards referenced (V.1.c)

• EN 301 549 v3.2.1 as the harmonised standard
• WCAG 2.1 Level AA as the underlying technical standard
• Any additional standards applied

4. Compliance status

For each applicable Annex I requirement:

• Compliant — the requirement is fully met
• Partially compliant — some aspects are met, with documented exceptions
• Non-compliant — the requirement is not met (with explanation)
• Not applicable — the requirement does not apply to this service

5. Exemptions (if any)

• If claiming disproportionate burden: detailed cost-benefit analysis
• If claiming microenterprise exemption: evidence of eligibility

Format requirements

The EAA does not mandate a specific file format, but the declaration must be:

• Publicly accessible — published on your website, easily findable
• In an accessible format — the declaration itself must meet accessibility standards
• Machine-readable (recommended) — JSON-LD format enables automated verification

A declaration is typically published in three formats:

• PDF — for printing and formal archiving
• HTML — for web publication (accessible, indexed by search engines)
• JSON-LD — for machine-readable structured data

Where to publish

Best practices for publication:

1. Dedicated URL — e.g., yoursite.eu/accessibility or yoursite.eu/eaa-declaration
2. Linked from the footer — every page should link to the declaration
3. Linked from legal/compliance pages — alongside privacy policy and terms of service
4. Submitted to national authority — some member states require direct submission

How RankProof helps

RankProof's free audit supports part of the declaration process:

1. Scans your website using industry-standard tools
2. Maps violations to Annex I requirements
3. Evaluates compliance for each requirement
4. Gives you the evidence to write the compliance-assessment section yourself
5. Leaves the versioning to you — re-run the audit whenever the service changes, and publish a new dated version of your declaration

Template structure

A well-structured Annex V declaration follows this outline:

1. Header — Document title, version, date
2. Provider information — Organisation name, address, contact
3. Service description — What is covered, scope, URLs
4. Standards applied — EN 301 549, WCAG 2.1 AA
5. Compliance assessment — Per-requirement status table
6. Non-compliance details — Specific issues and remediation plans
7. Exemptions — Disproportionate burden claims (if any)
8. Feedback mechanism — How users can report accessibility issues
9. Enforcement procedure — Link to national authority complaint process

Retention and updates

• Keep the declaration available for as long as the service is offered (Article 13(2)) — update it whenever the service changes materially
• Update after every significant change to the service
• Re-assess at least annually even without changes
• Version your declarations — maintain a history of compliance status over time