- An EAA compliance record is your documented evidence that products and services meet the accessibility requirements in Annex I of the European Accessibility Act.
- The core components are a technical assessment against Annex I, remediation history, and any disproportionate burden assessment under Annex VI.
- Service providers claiming disproportionate burden must renew that assessment at least every five years.
Creating an EAA compliance record means documenting how your product or service meets the accessibility requirements of the European Accessibility Act (EAA), and keeping that documentation current as things change. The EAA applies to products placed on the market, and services provided to consumers, after 28 June 2025, so the record is not a one-time file. It is a living account of your accessibility state, your evidence, and your reasoning.
What Goes Into an EAA Compliance Record?
The record should let a market surveillance authority, or a business customer, see exactly how you assessed accessibility and what you found. At minimum, it should contain:
- Identification of the products and services in scope, mapped to the EAA’s scope categories (for example, e-commerce services or consumer banking services).
- A technical assessment against the accessibility requirements in Annex I.
- The standard you assessed against, typically EN 301 549 or WCAG 2.1 AA / WCAG 2.2 AA for digital assets. Accessible.org recommends WCAG 2.1 AA or WCAG 2.2 AA as a technical standard for digital assets.
- Issue lists and remediation history, with dates.
- Any disproportionate burden or fundamental alteration assessment, with the Annex VI criteria applied.
- VPAT documentation. An ACR is a practical way to communicate WCAG conformance findings to buyers and authorities.
| Component | Basis and What It Covers |
|---|---|
| Annex I assessment | Documented evaluation of the product or service against the accessibility requirements stated in Annex I of the EAA. |
| Annex VI assessment | If you claim disproportionate burden, the assessment applies the criteria in Annex VI. Service providers must renew it at least every five years. |
| Technical standard evidence | Audit results against EN 301 549 or WCAG 2.1 AA / 2.2 AA, plus screen reader testing and keyboard testing notes. |
| Remediation log | Issues found, fixes made, retest results, and dates. Shows conformance is maintained, not claimed once. |
Which EAA Provisions Require Documentation?
The Annex I requirements are what your record must demonstrate. Annex II gives concrete illustrations of what those requirements look like in practice. Annex II offers this non-binding illustration for websites: “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.” Your record should show evidence for each of those areas.
If you rely on the disproportionate burden exception, the assessment itself becomes a mandatory part of your record, judged against the criteria in Annex VI. The directive’s recitals set a hard limit on weak reasoning: “Lack of priority, time or knowledge should not be considered to be legitimate reasons” for claiming disproportionate burden. And even where an exception applies, you must still apply the Annex I requirements that are not disproportionate, and document that you did.
Are Microenterprises Exempt From Documentation?
Partly. Article 3 of the directive defines a microenterprise as “an enterprise employing fewer than 10 persons with annual turnover not exceeding EUR 2 million or annual balance sheet total not exceeding EUR 2 million.” Microenterprises providing services are exempt from the accessibility requirements and related obligations. Microenterprises dealing with products are exempt from documenting their assessment, but must supply the facts of that assessment to a market surveillance authority on request. So even exempt product microenterprises should keep informal notes they can produce.
How Do You Build the Record? A Working Order
- Inventory every in-scope product and service and map each to its EAA category.
- Conduct a (manual) audit against WCAG 2.1 AA or WCAG 2.2 AA, or EN 301 549. Automated scans alone will not surface everything the Annex I requirements demand.
- Log every issue, then track remediation and retesting with dates.
- Document any Annex VI disproportionate burden assessment, and calendar its five-year renewal if you are a service provider.
- Produce an ACR from the VPAT so buyers and authorities can read your conformance state quickly.
- Review the record whenever the product or service changes materially.
A platform like Accessibility Tracker keeps the issue log, remediation history, and audit trail in one place, which is most of the record’s ongoing maintenance.
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