Use the EU edition of the VPAT when your buyer, contract, or market requires conformance reporting against EN 301 549, the European accessibility standard. The EU edition maps your product against EN 301 549 clauses, which include WCAG 2.1 Level A and AA plus additional requirements covering hardware, software, documentation, and support services. If your customer is a European public sector body, a procurement office subject to EU directives, or a private company preparing for European Accessibility Act obligations, the EU edition is the correct format. Other editions of the VPAT will not satisfy EN 301 549 procurement requirements.
The EU edition exists because EN 301 549 covers more than WCAG. Selecting the wrong edition can stall a procurement process or force you to redo the work.
| Question | Answer |
|---|---|
| What standard does it cover | EN 301 549, the harmonized European accessibility standard |
| When to select it | European procurement, EAA preparation, or contracts citing EN 301 549 |
| How it differs from WCAG edition | Includes WCAG 2.1 A and AA plus hardware, software, documentation, and support clauses |
| When the INT edition fits better | Selling into multiple regions and want WCAG, Section 508, and EN 301 549 in one document |
| Required input | A current accessibility evaluation against EN 301 549 or WCAG 2.1 AA at minimum |
What the EU edition of the VPAT actually contains
The EU edition follows the same template structure as the other VPAT editions, but the conformance tables map to EN 301 549 clauses rather than only WCAG success criteria.
EN 301 549 organizes requirements into chapters. Chapter 9 covers web content and aligns with WCAG 2.1 Level A and AA. Chapter 10 covers non-web documents. Chapter 11 covers non-web software. Chapter 12 covers documentation and support services. Chapter 13 covers ICT providing relay or emergency services.
For a SaaS product or website, Chapters 9, 11, and 12 are typically in scope. Chapter 9 captures WCAG requirements. Chapter 11 covers software accessibility points not already addressed by WCAG. Chapter 12 confirms that documentation and support are accessible.
When does the EU edition apply to your product?
The EU edition applies in three common scenarios.
First, European public sector procurement. EU directive 2016/2102 requires public sector bodies to procure ICT that conforms to EN 301 549. Vendors responding to these tenders are asked for EN 301 549 conformance documentation, which the EU edition provides.
Second, European Accessibility Act preparation. The EAA went into effect on June 28, 2025, and applies to many private sector products and services sold in the EU. EN 301 549 is the presumed method of demonstrating conformance with the EAA’s technical requirements. An EU edition ACR gives your team and your customers a structured record of where your product stands.
Third, European enterprise buyers. Even outside formal regulation, large European companies often request EN 301 549 documentation as part of their vendor review process.
EU edition vs. WCAG edition vs. INT edition
The WCAG edition maps only to WCAG 2.0, 2.1, or 2.2. It is the most common edition for SaaS companies selling primarily in the United States and for any buyer whose requirements stop at WCAG conformance.
The Section 508 edition maps to the U.S. federal Section 508 standard, which itself references WCAG 2.0 AA. It is used for U.S. federal procurement.
The INT edition combines WCAG, Section 508, and EN 301 549 into a single document. It is the right choice when you sell into multiple regions and want one ACR that satisfies most buyers. The tradeoff is length and complexity.
The EU edition isolates EN 301 549. It is the cleanest format when your buyer only cares about European requirements.
Do you need an evaluation before completing the EU edition?
Yes. A VPAT is a template. An ACR is the completed document, and a credible ACR is grounded in evaluation data. Without an evaluation, the conformance claims in the report are guesses.
For the EU edition specifically, the evaluation needs to cover the EN 301 549 clauses in scope for your product. At minimum, that means a WCAG 2.1 AA evaluation covering Chapter 9. For a software product, Chapter 11 clauses also need review. Documentation and support content covered by Chapter 12 should be evaluated as well.
Accessible.org conducts the evaluation work first, then prepares the ACR using the EU edition template when European conformance is the goal.
How long is an EU edition ACR valid?
ACRs do not carry a formal expiration date. The practical rule is to update the report after significant product changes or at least annually, whichever comes first. European buyers reviewing your documentation will look at the date on the report. A two-year-old ACR for a product that ships updates every month invites scrutiny.
If you have completed remediation since the original evaluation, a fresh evaluation followed by an updated ACR shows progress and current state.
How Accessible.org approaches EU edition reports
Accessible.org evaluations are fully manual and conducted by experienced auditors. For EU edition work, the evaluation covers WCAG 2.1 AA at the Chapter 9 level and extends into the relevant software and documentation clauses. The completed ACR reflects the evaluation findings clause by clause.
Pricing and turnaround depend on the scope of the product and the EN 301 549 chapters in play. The VPAT and ACR services overview walks through how the work is structured.
Is the EU edition the same as an EAA conformance certificate?
No. The EU edition of the VPAT is a self-disclosure document that reports product conformance against EN 301 549. The EAA does not issue conformance certificates in the way some product safety regimes do. The ACR is the documentation buyers and regulators look at when assessing accessibility.
Can a U.S. company use the EU edition?
Yes. The edition is selected based on the standard your buyer references, not your company’s location. A U.S. SaaS vendor selling into the EU public sector will use the EU edition for those contracts.
What if my product also needs to satisfy U.S. buyers?
Two options work here. You can prepare separate WCAG or Section 508 editions for U.S. buyers and an EU edition for European buyers. Or you can prepare a single INT edition that covers all three standards. The right path depends on how often each region requests documentation and how detailed each contract requires the report to be.
Does the EU edition require a different evaluation than the WCAG edition?
The evaluation scope is broader. A WCAG-only evaluation covers Chapter 9 of EN 301 549. The EU edition often calls for additional review of software, documentation, and support clauses that sit outside WCAG.
The right edition follows the buyer and the standard. When EN 301 549 is on the contract, the EU edition is the document that does the work.
Contact Accessible.org to start an EU edition ACR for your product.
