01Where the formal statement comes from
The accessibility statement as a legal document comes from Directive (EU) 2016/2102, which is about the websites and mobile apps of public sector bodies. Article 7(1) says those bodies must provide and regularly update a detailed, comprehensive and clear statement, published on the website in an accessible format. It must explain which parts of the content are not accessible and why, describe and link to a feedback mechanism, and link to the enforcement procedure. The Commission sets the model statement. Romania applies the Directive through Emergency Ordinance 112/2018, and the W3C policy page lists the Authority for Digitalisation of Romania (ADR) as a responsible entity. A typical private business is not a public sector body, so this duty does not reach its website. That does not mean no private duty exists, which is the next section.
- Directive 2016/2102, Article 7(1): public sector bodies publish and update a statement on their websites and mobile apps
- Contents: inaccessible parts with reasons, a feedback mechanism, a link to the enforcement procedure
- Romania applies it through Emergency Ordinance 112/2018, with ADR listed by the W3C as a responsible entity
- The Commission sets a model statement, so each body does not invent its own format
02What the European Accessibility Act covers
Directive (EU) 2019/882 had to be transposed by 28 June 2022 and its national measures apply from 28 June 2025. Romania's version is Law 232/2022. Article 2(2) of the Directive (Article 2(3) of Law 232/2022) lists the services in scope: electronic communications, access to audiovisual media, parts of air, bus, rail and waterborne passenger transport, consumer banking, e-books and dedicated software, and e-commerce services. Article 3 defines e-commerce services as services provided at a distance, through websites and mobile device-based services, at the individual request of a consumer, with a view to concluding a consumer contract. A consumer is a natural person acting outside their trade, business or profession. Our reading: a site that only presents your business is not on that list, while a shop or a pay-online flow for individuals is the kind of thing the definition describes. Whether yours counts is a question for a lawyer.
- Services in scope include e-commerce, consumer banking, e-books and electronic communications (Article 2(2) of the Directive, Article 2(3) of Law 232/2022)
- E-commerce services: at a distance, through websites, to conclude a consumer contract (Article 3)
- A consumer is a natural person acting outside their trade or business
- National measures apply from 28 June 2025; Romania's is Law 232/2022
03What you publish if you are in scope, and who is exempt
For an in-scope service, the duty sits in Article 13 and Annex V. The provider puts information in its general terms and conditions or an equivalent document: a general description of the service in accessible formats, the explanations needed to understand how it works, and a description of how the Annex I requirements are met. Romanian Law 232/2022 repeats the duty in Article 13(2), with the information public, in written and oral form, and kept while the service runs. So the law asks for information, not for a page called accessibility statement. Many businesses publish such a page anyway, which we think is sensible, but it is a choice, not a rule. Microenterprises are exempt: fewer than 10 persons and a turnover or balance sheet total not above EUR 2 million (Articles 3 and 4(5)). The Romanian Article 4(5) points to paragraph (3), which in the copy we read deals with urban, suburban and regional services, so check how far the exemption reaches.
- Annex V: a general description of the service, how it operates, and how the Annex I requirements are met, in the terms and conditions or an equivalent document
- Article 14: no duty where compliance means a fundamental alteration or a disproportionate burden, assessed in writing and kept five years
- In Romania, ADR is the designated authority for e-commerce services (Law 232/2022, Article 19(1)(d))
- Fines for breaching the Article 13 duties run from 5,000 to 15,000 lei depending on the breach (Article 27, as we read it); check the current text on legislatie.just.ro
04What a statement contains when you do publish one
The European Commission's own statement for its Implementing EU law website is a good shape to copy. It says which domain it covers, which standard it was measured against (EN 301 549 v3.2.1 and WCAG 2.1 level AA), what is not yet compliant (three named issues), the date of the last test (4 November 2024), how the assessment was made (an external contractor, a sample of pages, manual and automated tests), and how to report a barrier, with a reply target of 15 working days. Add what Directive 2016/2102 asks of public bodies: the inaccessible parts with reasons and alternatives, a feedback mechanism, and a link to the enforcement procedure. One rule matters more than the format. Every line must be something you tested. A statement that says the site is fully accessible, with no test behind it, is a claim you will have to defend.
- Scope: which domain the statement covers
- The standard tested against, the result and the date of the last test
- Known gaps, the reason for each and an accessible alternative
- A feedback channel with a stated reply time; public bodies also link the enforcement procedure
- Sources we read: eur-lex.europa.eu/eli/dir/2016/2102/oj, eur-lex.europa.eu/eli/dir/2019/882/oj, legislatie.just.ro/Public/FormaPrintabila/00000G3FI3Q2QUK0YX712TG2AHP8Q5TK (Law 232/2022), w3.org/WAI/policies/romania/, ec.europa.eu/implementing-eu-law/accessibility-statement/en
05Where PROOF48 is the wrong choice
PROOF48 builds websites: up to about five pages in 48 hours, 500 to 2,500 EUR, paid after you see the live preview. We do not sell accessibility audits, conformance testing or the writing of accessibility statements, and no plan or service page on this site lists them. So we are the wrong choice if you need your site tested against EN 301 549 or WCAG, or someone to stand behind a statement. That takes an accessibility auditor, and the legal side takes a lawyer. A store with cart and checkout is a different job, 2,500 to 4,500 EUR with its own timeline, and it is the kind of site the e-commerce definition describes, so raise the question before the build rather than after.
- A 48-hour website: up to about five pages, 500 to 2,500 EUR, paid after the preview
- No accessibility audits, conformance testing or statement writing at PROOF48
- Need testing or a signed statement: hire an accessibility auditor and a lawyer
- A store is 2,500 to 4,500 EUR with its own timeline, not the 48-hour site
A consumer ordering site is where the question starts
Rotiseria Baba Novac is a rotisserie in Bucharest. PROOF48 built its own ordering system: menu, cart, Stripe checkout, pickup slots and email confirmations, live at rotiseria.ro. A site that takes consumer orders online is the kind of build where the Act's e-commerce definition is worth checking early. The case study does not record any accessibility testing or statement, and it does not say whether the business counts as a microenterprise, so we claim none of that.
See the build: Rotiseria Baba NovacQuestions, answered
Does a microenterprise need an accessibility statement?
Directive 2019/882 Article 4(5) exempts microenterprises providing services from the accessibility requirements and the obligations tied to them. A microenterprise has fewer than 10 persons and a turnover or balance sheet total not above EUR 2 million. The Romanian wording of the exemption is worth confirming with a lawyer.
Does a simple brochure site with a contact form fall under the Act?
The Directive lists specific services, and e-commerce services are defined as services provided at a distance to conclude a consumer contract. A site that only presents a business is not on that list, in our reading. Confirm your case with a legal adviser.
Is an accessibility statement the same as an accessibility audit?
No. The audit or test produces the findings. The statement reports them: the standard used, what fails, the date and how to give feedback.
Who enforces this in Romania?
For e-commerce services, Law 232/2022 names the Authority for Digitalisation of Romania (ADR) in Article 19(1)(d). For public sector websites under Emergency Ordinance 112/2018, the W3C lists ADR as a responsible entity.
Does PROOF48 write accessibility statements?
No. We do not sell accessibility audits, testing or statement writing. We build websites, and the wording and legal weight of a statement are for you, an auditor and your legal adviser.
Where PROOF48 fits
A formal accessibility statement is a legal duty for public sector bodies. A private business owes information on how a listed service, such as e-commerce, meets the requirements, unless it is a microenterprise. A brochure site is not on the list, in our reading. Publish only what you have tested, and confirm your case with a lawyer. PROOF48 builds the 48-hour website for 500 to 2,500 EUR, and the testing and the legal wording are not ours to provide.
Cosmin Tiu · Founder, PROOF48
Cosmin has worked in online marketing and software development since 2018, and has built with AI every day since January 2023. He still writes code from scratch daily, in Python, React, Rust and C#. PROOF48 ships business websites in 48 hours and invoices afterwards, so every opinion on this blog was paid for in real builds, not in theory.