Our EAA compliance audits evaluate your digital services against the European Accessibility Act requirements.
Our manual evaluation identifies accessibility issues that could result in market surveillance actions, product recalls, or the significant penalties each member state will impose for non-compliance. Every audit is conducted by a technical accessibility expert who understand both Annex I technical requirements.
We evaluate against the accessibility requirements in Annex I, particularly Section III (general service requirements) and Section IV (specific service requirements), using the four WCAG principles embedded in the EAA: perceivable, operable, understandable, and robust. While the EAA doesn’t explicitly require WCAG conformance, these principles make WCAG 2.1 AA or WCAG 2.2 AA the practical technical standard for compliance—and we recommend advancing to WCAG 2.2 AA to align with the upcoming EN 301 549 v4.1.1 update.
After completing your EAA audit, we provide a detailed report documenting how your service meets each applicable requirement from Annex I. This documentation is essential for your conformity assessment and the accessibility information you must provide under Annex V. You can upload your audit report to Accessibility Tracker to organize remediation efforts and track progress toward compliance before the deadline.
Our audit reports include everything needed for EAA compliance documentation:
- What the issue is
- Where the issue is located
- Relevant Annex I requirement
- WCAG success criterion alignment
- Recommended fix
- Screenshot or screen recording of the issue
- Users affected
| Step | Action & Details |
|---|---|
| Step 1: Review Annex I Requirements | Identify which Annex I sections apply: Section III for all services, Section IV for specific service types |
| Step 2: Understand Annex I Examples | Review specific accessibility examples in Annex I such as screen reader compatibility, keyboard navigation, and alternative formats |
| Step 3: Apply POUR Principles | Organize requirements under Perceivable, Operable, Understandable, and Robust principles for systematic evaluation |
| Step 4: Test Against WCAG 2.1 AA | Evaluate all 50 success criteria of WCAG 2.1 AA which covers Annex I requirements and ensures presumption of conformity |
| Step 5: Conduct Technical Testing | Desktop: Windows, Chrome, NVDA. Mobile: iOS, Safari, VoiceOver. Include keyboard testing and automated scans |
| Step 6: Document Conformity | Prepare documentation showing how WCAG 2.1 AA conformance satisfies each Annex I requirement |
| Step 7: Deliver Compliance Report | Clear Excel spreadsheet ready for Accessibility Tracker upload with Annex V documentation requirements |
Table of Contents
Understanding EAA Requirements
Annex I Technical Requirements
The EAA sets accessibility requirements in Annex I that all covered services must meet. Section III establishes general requirements for all services, mandating that information be provided through multiple sensory channels, in understandable ways users can perceive, in text formats compatible with assistive technologies, and ensuring the service itself is perceivable, operable, understandable, and robust.
Section IV adds specific requirements for different service types—e-commerce must ensure accessible payment processes, banking services need accessible authentication, and telecommunications require accessible customer interfaces. Each service category has tailored requirements beyond the general obligations.
The WCAG Connection
While the EAA doesn’t explicitly incorporate WCAG, the EAA requires that websites and mobile applications be ‘perceivable, operable, understandable and robust’ – the same four principles underlying the Web Content Accessibility Guidelines (WCAG). This alignment makes WCAG 2.1 AA or WCAG 2.2 AA your practical roadmap for meeting EAA technical requirements.
The harmonized standard EN 301 549 currently incorporates WCAG 2.1 AA, and the standard is slated to be updated as part of supporting the implementation of the EAA and is in the process of being updated to include WCAG 2.2. We recommend targeting WCAG 2.2 AA now to future-proof your compliance efforts.
Process
1. Identify Your EAA Scope
We begin by identifying which products and services fall under EAA coverage and which Annex I sections apply. Section III establishes general requirements for all services, while Section IV adds specific requirements for different service types—banking, e-commerce, telecommunications, and transport.
2. Understand Annex I Requirements
Annex I requires services to provide information through multiple sensory channels, ensure text compatibility with assistive technologies, and make interfaces perceivable, operable, understandable, and robust. These functional requirements directly align with WCAG’s four POUR principles.
3. Audit Against WCAG 2.1 AA or WCAG 2.2 AA
We evaluate your service against all 50 success criteria of WCAG 2.1 AA or WCAG 2.2 AA. Since WCAG’s POUR principles match the EAA’s requirements, achieving WCAG conformance effectively satisfies Annex I. This approach aligns with EN 301 549, giving you presumption of conformity.
4. Set Testing Environments
We evaluate using assistive technologies recognized across the EU. Desktop environments include Windows with NVDA screen reader and Chrome. Mobile environments use iOS with VoiceOver and Safari. Mac desktop and Android mobile available as add-ons.
5. Conduct Comprehensive Testing
Our experts perform manual testing including keyboard navigation, screen reader compatibility, visual inspection, and code review. We test every WCAG success criterion to ensure your service meets the perceivable, operable, understandable, and robust requirements.
6. Automated Scan Review
We use the AXE automated scan tool as a final review to complement our manual audit process, ensuring comprehensive coverage of potential issues.
7.Deliver Audit Report
Our Excel audit report documents all accessibility issues with clear remediation guidance. Upload it directly to Accessibility Tracker to prioritize fixes and track progress toward your June 28, 2025 compliance deadline.
Post-Audit Support
Validation and Compliance Documentation
After receiving your audit report, your team will begin fixing identified issues. Most clients purchase technical support hours for validation of fixes. This ensures proper remediation and provides the documentation needed for your conformity assessment under Annex IV (for products) or Annex V (for services).
Validation creates evidence that you’ve met EAA requirements—essential documentation for market surveillance authorities. The cost depends on technical support hours needed, typically 5 hours or fewer.
Preparing for Market Surveillance
EU member states will conduct market surveillance to ensure compliance. Having comprehensive audit documentation and validation records demonstrates your commitment to accessibility and provides essential evidence if authorities request your conformity assessment.
Investment in EAA Compliance
We’ve helped organizations prepare for EAA compliance through comprehensive audits aligned with Annex I requirements. Each audit follows rigorous processes that satisfy both technical requirements and documentation obligations. We can help with other accessibility services beyond audits. We recommend our VPAT service to bolster your documentation with an ACR.
EAA compliance audits typically range from $1,500 to $5,500, depending on service complexity, number of pages/screens audited, and which Annex I sections apply to your organization. With a 1-2 week turnaround, you’ll have clarity on your compliance status well before the June 28, 2025 deadline.
Critical EAA Compliance Questions
How Do Annex I Requirements Relate to WCAG?
Annex I Section III requires services to be perceivable, operable, understandable, and robust—the four WCAG principles. While the EAA doesn’t mandate specific WCAG conformance, meeting WCAG 2.1 AA or WCAG 2.2 AA effectively satisfies these functional requirements.
Why Recommend WCAG 2.2 AA Over 2.1 AA?
We anticipate WCAG 2.2 AA may effectively become the technical standard for a presumption of conformity.
How Will Member States Enforce the EAA?
Each EU member state sets its own penalties described as “effective, proportionate and dissuasive.” Market surveillance authorities can require remediation, recall products, prohibit sales, and impose financial penalties. Having audit documentation demonstrates proactive compliance efforts.
Does the EAA Apply to Non-EU Companies?
Yes. Any organization providing products or services to EU consumers must comply, regardless of where they’re based. This includes e-commerce platforms, digital services, and apps accessible from the EU.
What About Microenterprises?
Microenterprises (fewer than 10 employees AND less than €2 million annual turnover) providing services are exempt.
Service
Contact us for a proposal and we’ll help you meet Annex I requirements and prepare essential compliance documentation.
