- An EAA compliance record is your documented evidence that your product or service meets the accessibility requirements in Annex I of the European Accessibility Act (EAA).
- The core contents: an accessibility assessment, audit results against a technical standard like WCAG 2.1 AA or EN 301 549, remediation history, and any disproportionate burden assessment.
- Microenterprises providing services are exempt, but most economic operators need this file ready for market surveillance authorities.
Creating an EAA compliance record means assembling documented proof that your product or service meets the accessibility requirements of the European Accessibility Act, and keeping that proof current. There is no single mandated file format, so the practical move is to build a compliance file around an accessibility assessment, audit reports, remediation records, and any exception assessments.
| Component | What It Means for You |
|---|---|
| Accessibility assessment | A documented evaluation of your product or service against the Annex I requirements. |
| Audit report | Results of a (manual) audit against WCAG 2.1 AA, WCAG 2.2 AA, or EN 301 549, listing issues found. |
| Remediation history | A log showing which issues were fixed, when, and how they were retested. |
| ACR / VPAT | An ACR (a completed VPAT) that reports conformance in a recognized format buyers and authorities understand. |
| Exception assessments | Any disproportionate burden or fundamental alteration assessment, evaluated against the criteria in Annex VI. |
What Does the EAA Actually Require You to Document?
The EAA states its accessibility requirements in Annex I and illustrates them with examples in Annex II. Your record needs to show how you meet those requirements. For websites and apps, Annex II describes the target plainly: “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.” (Annex II)
WCAG conformance at level 2.1 AA or 2.2 AA is the practical way to evidence those points for digital assets. Accessible.org recommends WCAG 2.1 AA or WCAG 2.2 AA as a technical standard for digital assets, and EN 301 549 maps to the same territory for ICT products and services.
How Do You Build the Record?
- Inventory the digital assets and products in scope: websites, mobile apps, e-commerce flows, self-service terminals.
- Have a (manual) audit conducted against WCAG 2.1 AA or EN 301 549 and keep the full report.
- Track remediation of every issue through to retest, with dates. A platform like Accessibility Tracker keeps this history in one place.
- Produce an ACR from the audit results so you have a recognized conformance document.
- Document any exception assessment against Annex VI, and schedule its renewal. Service providers must renew a disproportionate burden assessment at least every five years.
Who Can Skip Parts of This?
Exemptions are narrow, and the record still matters:
- Microenterprises providing services are exempt from the accessibility requirements and the related obligations.
- Microenterprises dealing with products get lighter obligations and are exempt from documenting their assessment, but must supply the assessment facts to a market surveillance authority on request.
- Claiming disproportionate burden requires a real assessment. The directive is blunt on this in its recitals: “Lack of priority, time or knowledge should not be considered to be legitimate reasons” for claiming it.
Even where an exception applies, you must still make the product or service as accessible as possible by applying the requirements that are not disproportionate, and your record should show that.
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.
Related: ada compliance.
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