In the first of this three-part EAA documentation series, we covered documents and administrative obligations under the European Accessibility Act (EAA). We use the word ‘obligations’ to refer to the paperwork side of compliance and ‘requirements’ to refer to the technical accessibility standards — the material side of EAA compliance.
Some documents may not be legally required under the EAA but are still considered best practices for demonstrating good-faith compliance. We recommend organizing your records into the following folders, each potentially containing the listed key supporting documents.
Statements
| Document | Plain English Explanation |
|---|---|
| EU Declaration of Conformity | A legal document where you formally state that your product or service meets EAA requirements. It must be signed and dated. |
| CE marking documentation | Records showing the CE mark was applied properly, including who is responsible and confirmation that the product complies. |
| Accessibility statement | A statement explaining your accessibility efforts, posted on your website or materials, with a record of updates. |
| Disproportionate burden assessments | Document explaining if full compliance isn’t possible due to excessive cost or resources, and how you evaluated that. |
| VPATs / ACRs | Formal reports (optional under EAA) that show how your product aligns with accessibility standards like WCAG. |
| Third-party certification | Documentation or badges showing external experts have reviewed or certified your product for accessibility. |
- EU Declaration of Conformity (Annex V), signed and dated
- CE marking documentation, including responsible party and statement of conformity
- Public-facing accessibility statement and version history
- Disproportionate burden assessments, with rationale and updates
- VPATs / ACRs (Accessibility Conformance Reports)
- Certification from third-party providers
Accessibility
| Document | Plain English Explanation |
|---|---|
| Accessibility feature description | Explain what makes your product accessible, such as keyboard navigation, screen reader support, etc. |
| Audit and testing reports | Formal reviews and tests showing where accessibility works or needs improvement, ideally involving people with disabilities. |
| Remediation progress log | Ongoing logs that track accessibility issues and how/when they were fixed. |
| Process integration | Show how accessibility is built into your workflow, like checklists in design reviews or dev sprints. |
| User accessibility guidance | Guides that help users with disabilities use your product’s accessibility features. |
| Fix/change log | A record of updates made to improve accessibility — helps show your active efforts. |
- Technical description of accessibility features for each product/service
- Accessibility audit and user testing reports
- Progress tracking and remediation updates
- Integration of accessibility into design and development processes
- User-facing instructions or accessibility guidance
- Documentation of accessibility fixes and changes over time
Planning
| Document | Plain English Explanation |
|---|---|
| Accessibility policy | Your company’s written rules and methods for handling accessibility. |
| Procurement requirements | Accessibility criteria you apply when buying software, hardware, or services. |
| Implementation plan | Document showing how you plan to meet EAA obligations — what will be done, by who, and when. |
| Accessibility improvement schedule | Timeline showing your planned accessibility work, like audits, fixes, and milestones. |
| Versioning and meeting notes | Record changes and discussions to show decisions were made with accessibility in mind. |
| User request response process | Written process explaining how user accessibility issues are logged, handled, and resolved. |
- Accessibility policy and internal procedures
- Procurement requirements
- Compliance and implementation plan
- Schedule or roadmap for accessibility improvements
- Version control and meeting notes on accessibility decisions
- Process for responding to user accessibility requests
Contracts
| Document | Plain English Explanation |
|---|---|
| Vendor and consultant contracts | Make sure your contracts include accessibility responsibilities for anyone working on your product. |
| Agreements with authorized representatives | Contracts showing who’s acting on your behalf in the EU, if applicable. |
| Partner/supplier agreements | Include EAA compliance expectations in agreements with partners or suppliers who impact the product. |
- Consultant, developer, and vendor contracts with accessibility requirements
- Agreements with authorized representatives
- Partner and supplier agreements referencing EAA requirements
Compliance
| Document | Plain English Explanation |
|---|---|
| Regulatory communications | Emails or letters sent to government officials, and your responses to accessibility inquiries. |
| Complaint and action records | Track all complaints received about accessibility and how you responded. |
| CE and supply chain records | Record of who applied the CE mark and who you got the product from or sold it to. |
| Staff training records | Proof that your team has been trained on accessibility responsibilities. |
| Accessibility investment records | Receipts or records showing you invested in accessibility efforts. |
| Internal compliance reviews | Reports or summaries showing how your team checks whether you’re still in compliance. |
| Annual compliance report | A yearly overview of your EAA activities, progress, and remaining gaps (not required but helpful). |
| Disproportionate burden assessment | All calculations, independent advisor analysis, and the balance of accessibility measures not considered a disproportionate burden. |
- Communications and responses to regulatory authorities
- Complaint logs and corrective action records
- CE marking and supplier/customer identification logs
- Staff training records on EAA compliance and accessibility
- Evidence of accessibility-related investments (tools, services, training)
- Internal reviews or audits of compliance status
- Annual EAA compliance summary reports
- Full documentation and calculations from disproportionate burden assessment
Why This Documentation
Creating and retaining clear, well-organized documentation — such as audit reports, declarations of conformity, internal policies, and complaint logs — is not just a best practice under the European Accessibility Act (EAA); these documents can be practical difference-makers when facing potential market surveillance or enforcement actions. Under Article 19, surveillance authorities are empowered to request and review a wide range of internal assessments, including those related to disproportionate burden claims and compliance with accessibility requirements. If this documentation is missing or incomplete, economic operators may be unable to demonstrate how or why their product meets the Directive — increasing the risk of being found non-compliant.
Article 20 lays out a national procedure for dealing with non-compliant products. If a surveillance authority has reason to believe your product violates the EAA, they will evaluate all relevant documentation — including records of how accessibility was implemented, assessed, and monitored. Retaining versioned records like remediation logs, accessibility statements, or VPATs gives your organization the ability to show that corrective action was taken proactively or in response to issues. These documents provide a clear paper trail of due diligence, which can help avoid or mitigate regulatory demands such as forced withdrawal of a product from the market.
Moreover, Article 21 describes a Union-wide safeguard mechanism triggered when disputes arise about enforcement decisions. If an issue escalates beyond national borders, the Commission may evaluate the justification for enforcement across the EU. In these situations, having standardized, defensible documents — such as an accessibility policy, internal procedures, or third-party certifications — strengthens your position. It shows your organization followed consistent processes and made reasonable efforts to comply, which could be decisive in multi-country evaluations or appeals.
In short, the documents outlined in our recommended folders serve as the backbone of your compliance defense. They not only support good internal governance and accessibility outcomes, but also equip your team to respond quickly and credibly to regulators. Without this documentation, you’re effectively asking authorities to take your word — and under the EAA’s enforcement structure, that will fare poorly.
Services
If you need help with EAA documentation and project management, we’d be happy to streamline your compliance efforts.
Working with Accessible.org has the dual benefit of advancing both accessibility and compliance.
Working with a reputable, independent accessibility company is one of the clearest ways to demonstrate a genuine commitment to accessibility and a good faith effort toward compliance. It shows that accessibility is being addressed with the seriousness and expertise it requires.
Accessible.org offers not only high-quality services but also a deep understanding of the European Accessibility Act, based on close, detailed study of the Directive itself. This insight allows us to go beyond technical fixes — we help organizations think through how to document their efforts, how to structure internal processes, and how to review ongoing compliance in a way that aligns with real-world enforcement expectations.
We can assist with organizing and reviewing accessibility documentation, advising on internal procedures, and consulting on best practices for implementation, monitoring, and long-term oversight. Our approach is practical, standards-based, and tailored to support meaningful accessibility, not just box-checking.
To ask how we can help, just send us a message below or visit our contact page and we’ll be right with you.
