No, the European Accessibility Act (EAA) does not require a VPAT or ACR. The EAA has its own conformance framework rooted in EN 301 549, and it does not reference the Voluntary Product Accessibility Template at any point. That said, an ACR can still serve a practical purpose for organizations operating in both U.S. and European markets.
The distinction matters because procurement teams, legal departments, and product managers frequently conflate U.S. documentation formats with European requirements. They are separate systems with different expectations.
| Question | Answer |
|---|---|
| Does the EAA require a VPAT? | No. The EAA does not reference or require a VPAT. |
| What standard does the EAA use? | EN 301 549, which maps to WCAG 2.1 AA for web and mobile content. |
| Is an ACR useful for EAA compliance? | It can be, especially for SaaS companies selling into both U.S. and EU markets. |
| What documentation does the EAA expect? | Conformity declarations, CE marking, and technical documentation showing EN 301 549 conformance. |
| When did the EAA go into effect? | June 28, 2025. |
What the EAA Actually Requires for Documentation
The EAA went into effect on June 28, 2025. It applies to products and services sold within the European Union, including websites, mobile apps, e-commerce platforms, and digital banking services.
Under the EAA, organizations must demonstrate conformance with EN 301 549. The documentation path looks different from what U.S.-based companies are used to. Instead of a VPAT or ACR, the EAA expects:
A Declaration of Conformity stating the product or service meets applicable accessibility requirements.
CE marking where applicable to products.
Technical documentation that describes how accessibility requirements have been met, including the standards used and evaluation methods.
None of these documents follow the VPAT format. They are structured around EU product conformity frameworks, not U.S. procurement templates.
Why Do People Assume a VPAT Is Needed?
The confusion comes from how deeply the VPAT/ACR process is embedded in U.S. accessibility procurement. Section 508 requires federal agencies to consider ACRs when purchasing technology. Over time, the VPAT became shorthand for “proof of accessibility” across markets.
When the EAA started gaining attention, many product teams assumed the same documentation would apply. It does not. The EAA is a European regulation with its own structure, enforcement mechanisms, and conformity pathways.
That said, the underlying technical standard is familiar. EN 301 549 maps its web and mobile requirements to WCAG 2.1 AA. So the accessibility work is largely the same. The difference is how conformance gets documented and who reviews it.
Can an ACR Still Be Useful for EAA Compliance?
Yes, in a practical sense. An ACR documents accessibility conformance against a specific standard, typically WCAG 2.1 AA or WCAG 2.2 AA. If your organization already has an ACR from an accessibility audit conducted by a qualified auditor, that data is directly relevant to your EAA obligations.
The ACR itself will not satisfy EAA documentation requirements on its own. But it provides the technical foundation. The audit data inside an ACR, the identified issues, the conformance levels per criterion, and the evaluation methods, can feed directly into the technical documentation the EAA expects.
For SaaS companies and digital product vendors operating in both the U.S. and EU, maintaining an ACR alongside EAA-specific documentation is efficient. You complete one (manual) accessibility audit, and the results inform both documents.
EN 301 549 and WCAG 2.1 AA: The Common Thread
EN 301 549 is the European standard for ICT accessibility. For web content and mobile applications, it incorporates WCAG 2.1 Level AA. This means an organization that conforms to WCAG 2.1 AA has already addressed the core web accessibility requirements under EN 301 549.
EN 301 549 goes further than WCAG in some areas. It covers hardware, telecommunications, and non-web software interfaces. But for digital services like websites, web apps, and mobile apps, WCAG 2.1 AA is the operative standard.
Accessible.org audits evaluate against WCAG 2.1 AA and WCAG 2.2 AA. Organizations preparing for EAA compliance can use the same audit results to build their conformity documentation.
How to Approach EAA Documentation Without a VPAT
If you are preparing for EAA compliance and wondering where to start, the path is clear:
- Complete a (manual) accessibility audit of your digital product against WCAG 2.1 AA or WCAG 2.2 AA
- Remediate identified issues to bring the product into conformance
- Prepare your Declaration of Conformity and supporting technical documentation based on audit results
- If you also sell into U.S. markets, consider having an ACR completed using the VPAT template from the same audit data
The audit is the foundation for everything. Without a thorough (manual) evaluation, neither an ACR nor an EAA conformity declaration carries weight.
What About the VPAT INT Edition?
The VPAT has four editions: WCAG, Section 508, EN 301 549, and INT (International). The INT edition combines all three standards into a single document.
Some organizations use the INT edition to create a single ACR that covers WCAG, Section 508, and EN 301 549 simultaneously. This can be helpful for multinational companies that want one document to reference across markets.
But even with the INT edition, an ACR is not what the EAA requires. It is a supplementary document. European regulators and market surveillance authorities expect conformity documentation formatted to EU standards, not a U.S. procurement template.
The INT edition is most useful when responding to procurement requests from buyers who want to see EN 301 549 conformance in a familiar format. Accessible.org produces ACRs in all four VPAT editions depending on client needs.
FAQ
Should I get an ACR if I only sell in the EU?
Not necessarily. If your market is exclusively European, your documentation obligations come from the EAA and EN 301 549 conformity frameworks. An ACR is optional. However, if EU-based procurement teams request one, having an ACR available demonstrates conformance in a widely recognized format.
Does EN 301 549 require WCAG 2.2 AA?
The current version of EN 301 549 references WCAG 2.1 AA for web and mobile content. WCAG 2.2 AA is not yet formally required under EN 301 549, though future updates to the standard may incorporate it. Many organizations are already auditing against WCAG 2.2 AA to stay ahead of that shift.
Can a scan replace an audit for EAA documentation?
No. Automated scans only flag approximately 25% of issues. A scan cannot determine WCAG conformance, and conformance is exactly what the EAA requires you to demonstrate. A (manual) accessibility audit is the only way to determine WCAG conformance and produce reliable data for your EAA compliance documentation.
How often should EAA conformity documentation be updated?
ACRs do not have a formal expiration. The same principle applies to EAA documentation. Update your conformity declaration and technical documentation after significant product changes, major feature releases, or updates to the underlying accessibility standard.
The EAA created a new compliance framework for digital products in Europe. While a VPAT or ACR is not part of that framework by default, the accessibility work underneath is the same. A strong audit and remediation process positions your organization for both U.S. and EU requirements without duplicating effort.
Contact Accessible.org about accessibility audits, ACRs, and EAA compliance documentation.
