Accessibility Statements: Test Records and Updates
An accessibility statement should explain the tested state of your service. When a checkout, form or cookie banner changes, check whether the published information still reflects it.
The Statement Generator supports drafting from audit data. Before publication, add manual test results and information about your service, then review the text.
What Section 14 BFSG requires
For covered services, Section 14(1) requires accessible information under Annex 3(1). This includes a general description, explanations of how to use the service, information on meeting the requirements and the responsible market surveillance authority. Section 14(3) requires procedures for continued adherence, taking changes to the service and relevant standards into account. It does not set a fixed statement update interval.
A snapshot versus a maintained draft
“Static” and “dynamic” describe working practices here, not statutory document types. A manually maintained page can also be updated after review.
| Step | One-time snapshot | Regularly reviewed draft |
|---|---|---|
| Test basis | One documented test state | New findings are compared with the previous state |
| After a release | Information remains unchanged without further review | An owner reviews relevant changes |
| Manual tests | Part of the original assessment | Repeated for changed journeys |
| Publication | Editorially approved text | Revised text after renewed approval |
A new scan can detect missing form labels. It cannot judge whether the entire purchase journey makes sense with a screen reader. Both results must inform the assessment. The WCAG overview helps you interpret the technical criteria.
Example: A checkout changes
- Test: Scan the changed checkout with the Accessibility Audit. Also test with a keyboard and screen reader, including error messages and payment completion.
- Document: Record tested URLs, date, version, findings and outstanding limitations. Assign an owner to each open issue.
- Update the draft: Add confirmed results to the statement draft. Fixing one scan finding does not establish that the whole journey has been tested.
- Approve and publish: Check the description, contact options and service information. Publish the approved version and retain the previous test record.
Schedule this review for relevant releases. Name the person who approves the text and a trigger for the next assessment, such as navigation, form or purchase flow changes. Readers and colleagues can then understand which tests support your information.
Questions about updates
No. It provides a draft. You must check the information, add manual findings and assess the legal requirements for your service.
The workflow described here includes review and approval. New scan data informs revisions; it does not establish that all requirements are met.
Further reading and sources
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