What is an Accessibility Statement?
An accessibility statement is a mandatory document describing the extent to which a website or mobile application complies with web accessibility requirements. The Danish Agency for Digital Government compares it to a product label: it must inform citizens what is accessible, what is not — and what the authority is doing about it.
The requirement stems from the Web Accessibility Act (Act No. 692 of 8 June 2018), which implements EU Directive 2016/2102 in Danish law. Detailed rules are set out in the executive order on the submission of accessibility statements for public sector bodies’ websites and mobile applications. The statement must meet the standard established by the European Commission in Implementing Decision (EU) 2018/1523.
WAS-Tool: How to Create the Statement
Public authorities and public law bodies are required to create their accessibility statement using the Danish Agency for Digital Government’s digital solution, WAS-Tool. The system is available at was.digst.dk and automatically generates a standardised URL in the format was.digst.dk/[website-name] — for example was.digst.dk/digst-dk for the Agency’s own website.
The statement must be linked directly from the website’s footer. For mobile applications, the link may be placed in the app store (App Store/Google Play) or on the authority’s website. Each independent website and each mobile app must have its own statement — a single statement cannot cover multiple solutions.
Private organisations are not covered by the Web Accessibility Act and may not use WAS-Tool. Private companies wishing to publish an accessibility statement voluntarily must create their own — and these must not be designed in a way that could be confused with statements created in WAS-Tool.
The Three Categories of Non-Accessible Content
The core of the accessibility statement is a categorised overview of content that does not meet the legal requirements. The Agency for Digital Government operates with three distinct categories, each serving a precise purpose:
Step 4.1 — Does not comply with the Web Accessibility Act: This is where content falling within the scope of the Act but not yet meeting its requirements is declared. Examples include self-service solutions with inadequate keyboard navigation, videos without subtitles, or PDF documents without accessible structure. Each item should in principle be described with a title, its location on the website, and specification of which WCAG requirements are not met.
Step 4.2 — Disproportionate burden: The Act allows authorities to refrain from making specific content accessible if doing so is assessed to constitute a disproportionate burden — for example, a very large archive with a limited readership. The assessment is case-specific and must be weighed against the disadvantage experienced by a person with a disability who cannot access the content. If this exception is invoked, the statement must indicate whether an accessible alternative has been provided.
Step 4.3 — Not covered by the Act: Certain types of content are exempt from the Act — including map applications, live-streamed videos, and older archive material that is no longer updated. Content in this category must still be listed, so it is clear to citizens that the authority has made a concrete assessment.
Where an authority has nothing to declare within a given category, this must be explicitly marked in WAS-Tool as “nothing to report.” This matters — an empty category without that marking gives citizens no assurance that an assessment has actually been carried out.
Contact Information and Response Deadlines
The statement must include both telephone and written contact details so that citizens can report accessibility barriers. The written contact option must not require users to log in with MitID or pass through non-accessible verification mechanisms — such as non-accessible CAPTCHA solutions.
The response time for accessibility enquiries is set at a maximum of four weeks. If a citizen finds the authority’s response unsatisfactory, the matter can be referred to the Agency for Digital Government at webtilsyn@digst.dk or by phone on +45 20 16 36 12. The Agency uses these enquiries as input to its ongoing monitoring work.
Compliance Status and Evaluation Method
The statement must specify the extent to which the website complies with the harmonised European standard EN 301 549 v.3.2.1, which refers directly to WCAG 2.1. Compliance status can be recorded at three levels: fully conformant, partially conformant, or non-conformant.
The statement must also describe how accessibility has been evaluated. Options include self-assessment, assessment by an external party, or a combination. The Agency for Digital Government recommends that the evaluation be documented as concretely as possible — and that links to any test reports be included where available.
PDF Documents in the Statement
PDF documents present a particular challenge when it comes to the accessibility statement. Many authorities hold large archives of older PDF files that are neither tagged nor compliant with the PDF/UA standard — and are therefore inaccessible to screen readers.
Such documents must either be declared under step 4.1 as non-accessible content with a remediation plan, assessed as a disproportionate burden under step 4.2, or exempted as archive material under step 4.3 if they meet the conditions for this. A practical first step towards reducing the volume of non-accessible PDF content is to convert existing documents to WCAG 2.1 AA-compatible HTML — something PDFAccess does directly in the browser without any server upload.
Updating and Dating the Statement
The statement must indicate when it was first published and when it was most recently revised. It is a legal requirement that the statement be kept up to date — in practice, it should be reviewed whenever significant changes are made to the website, and at least once a year.
The Agency for Digital Government continuously draws samples from WAS-Tool for its supervisory work. Authorities selected for monitoring receive a report with results and are offered a voluntary guidance meeting with the Agency and the consultancy consortium that carries out the monitoring.
Checklist: Is Your Accessibility Statement Complete?
- Statement created in WAS-Tool and accessible at the standardised URL
- Website footer links directly to the statement
- Each independent website and mobile app has its own statement
- Compliance status is stated (fully / partially / non-conformant)
- Evaluation method is described — internal, external, or combined
- Non-accessible content is correctly categorised under steps 4.1, 4.2, and 4.3
- Categories with no content are marked as “nothing to report”
- Contact information includes both telephone and written address without MitID requirement
- Date of first publication and most recent revision are stated
- Statement has been revised within the past year