- Proof of European Accessibility Act (EAA) compliance is documentary: an accessibility statement, technical records, and a conformity assessment you can produce on request.
- WCAG 2.1 AA or WCAG 2.2 AA conformance, verified by audit, supports the technical requirements behind that documentation.
- Microenterprises providing services are exempt, but product operators must still supply their assessment facts to authorities.
You show proof of EAA compliance with documentation, not a certificate. The European Accessibility Act (EAA) does not issue a stamp of approval, so proof means keeping records that demonstrate your product or service meets the accessibility requirements, plus a public accessibility statement describing how you meet them. An audit against WCAG and EN 301 549 produces the evidence those records rest on.
Accessible.org recommends WCAG 2.1 AA or WCAG 2.2 AA as a technical standard for digital assets, and that conformance is what your documentation should reference.
| Proof Element | What It Means for You |
|---|---|
| Accessibility statement | A public-facing document describing how your service meets the accessibility requirements. |
| Technical documentation | Internal records showing which requirements apply and how each is met. |
| Conformity assessment | The evaluation demonstrating the product or service conforms, retained and available on request. |
| Audit evidence | WCAG conformance results and remediation history that back up the claims above. |
What documentation does the EAA expect?
The EAA works through economic operators: manufacturers, importers, distributors, and service providers. Each keeps records appropriate to their role. Service providers publish information explaining how the service meets the accessibility requirements and keep it for as long as the service operates.
The following documents together form the backbone of your proof:
- An accessibility statement written in plain language that anyone can understand.
- Technical documentation mapping each applicable Annex I requirement to how you satisfy it.
- Audit reports and screen reader testing or keyboard testing results.
- A record of any disproportionate-burden assessment, where you rely on that exception.
For teams keeping these documents current, our Accessibility Tracker platform helps with tracking accessibility and compliance progress over time.
How does WCAG and EN 301 549 fit the proof?
The EAA states requirements in Annex I and gives illustrative examples in Annex II. Those examples read like WCAG in practice. One Annex II website example describes:
“Providing text description of pictures, making all functionality available from a keyboard, giving users enough time to read, making content appear and operate in a predictable way, and providing compatibility with assistive technologies, so that persons with diverse disabilities can read and interact with a website.”
That is WCAG conformance described in plain terms. EN 301 549 is the European standard for ICT products and services, and a revision targeting V4.1.1 supports Directive (EU) 2019/882. Documenting WCAG 2.1 AA or 2.2 AA conformance is the practical route to evidencing the technical side.
What steps produce credible proof?
Building defensible proof of EAA compliance follows a clear order:
- Confirm your product or service falls within EAA scope and identify your operator role.
- Conduct an accessibility audit against WCAG 2.1 AA or WCAG 2.2 AA.
- Complete remediation and re-test the fixed issues.
- Map each applicable Annex I requirement to your evidence in technical documentation.
- Publish an accessibility statement and retain your conformity assessment.
Many organizations record WCAG conformance in a VPAT, producing an ACR that documents each success criterion. That ACR sits alongside your accessibility statement as supporting evidence.
What about exemptions and disproportionate burden?
Microenterprises providing services are exempt from the accessibility requirements and related obligations. Product-side microenterprises get lighter obligations but must supply their assessment facts to a market surveillance authority on request.
Requirements also apply only where they do not impose a disproportionate burden. That claim must be assessed and documented, and it is limited. The Directive is explicit:
“Lack of priority, time or knowledge should not be considered to be legitimate reasons” for claiming disproportionate burden. Even where an exception applies, you must still make the product or service as accessible as possible.
Frequently asked questions
Does the EAA give a compliance certificate?
No. Proof is documentation you maintain and produce on request, not a certificate the EAA issues.
Is WCAG conformance enough on its own?
WCAG conformance supports the technical requirements, but you still need an accessibility statement and technical documentation to complete the proof.
When did the EAA take effect?
It applies to products placed on the market and services provided to consumers after 28 June 2025, so it is currently in effect.
How often should proof be refreshed?
Service providers must renew a disproportionate-burden assessment at least every five years, and audits should follow any significant code, design, or content change.
Get Started
Do you need help with EAA Compliance? Contact us to ask about an audit or other services.
Our Accessibility Tracker platform also helps track EAA compliance. Sign up for a free plan at AccessibilityTracker.com.
For a closer look at this, see our overview of ada compliance.
