Accessibility of services: what are the reporting requirements?

There may be some confusion between the reporting requirements for the accessibility of public sector websites and apps and those for services subject to the law of March 8, 2023, which implements the European Accessibility Act (EAA). We take stock of the situation in this article.

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Is it necessary to publish an accessibility statement?

For services

If you manage a service subject to the law of March 8, 2023, the OSAPS does not require an accessibility statement!

This applies to the following types of services: e-commerce, e-banking, e-books, audiovisual services, transportation, and emergency numbers.

However, you must comply with the reporting obligations set out in Article 15 (2) and Annex II of this law.

For each service you offer, you must publish an information sheet on the accessibility of the service in the legal notices for the service or any other equivalent document, including the following elements:

  1. A description of the applicable requirements;
  2. a general description of the service;
  3. the descriptions and explanations necessary to understand how the service works;
  4. A description of how the service meets accessibility requirements, i.e., the level of compliance achieved with current standards and a list of remaining non-compliances.
  5. information demonstrating that the service delivery process and its monitoring ensure compliance with reporting obligations and applicable legal requirements.

This information must be published in an accessible format. To this end, we recommend avoiding the PDF format, which is costly to make and maintain accessible, and instead publishing the information on a web page. It is entirely possible to dedicate an "accessibility" page on your website to this purpose.

This information must be kept for as long as the service is available.

It must, of course, reflect the accessibility of the service and be updated regularly.

To help you publish this information, OSAPS offers an optional template (Word, 17 Kb). You can, of course, structure the information required by law as you see fit without following this template. For banking services in particular, please feel free to contact ABBL, which has defined a specific template.

In order to produce such an information sheet, it is necessary to have carried out or had experts carry out a compliance audit and to maintain an up-to-date register of non-compliances. A template is available for the register of non-compliances on the non-compliance declaration page.

If your service does not comply with legal requirements, compliance with reporting obligations is not sufficient; you must also submit a non-compliance declaration to OSAPS.

Regarding current standards

The EN 301 549 v3.2.1 standard is currently in force for the accessibility of products and services throughout Europe and will be updated to v4.1.1 in September 2026. As it is already in force, this means that you can assess the compliance of your services with it.

Other standards will be added in 2026 and 2027, particularly for requirements relating to support services and level B2 for the description of banking services.
Follow our news to stay up to date with developments in regulatory requirements on our website in the "News" section and on our LinkedIn page.

For public sector websites and apps

If you manage a public sector website or app, you are subject to the law of May 28, 2019, and as such, you must publish an accessibility statement. This statement is made following a compliance audit and must explain in detail the level of compliance achieved and any accessibility issues, allow those concerned to contact you in the event of a problem, and provide information on remedies in the event of a dispute. The SIP provides a multilingual generator for your statement. Once the statement has been published, you have one month to inform the SIP by sending an email to accessibilite@sip.etat.lu .

A public sector website or app may contain one or more services subject to the law of March 8, 2023. In this case, both laws apply, for example, to the website of a public sector concert hall that offers an e-commerce service for the sale of its tickets.

In this case, it is necessary to make an accessibility statement as a public sector website or app and to include the information required for each service under the law of March 8, 2023.

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