Organizations covered by the European Accessibility Act (EAA) need documented proof that their digital products and services meet the accessibility requirements set out in the Directive. That proof takes different forms depending on whether you offer products or services, and includes the EU declaration of conformity, technical documentation, Annex V service information, accessibility audit reports, ACR documentation, and remediation records. Without this documentation, a claim of compliance carries no weight with market surveillance authorities or procurement buyers.
The EAA went into effect on June 28, 2025, and applies to a wide range of products and services sold within the European Union. If your web app, mobile app, ecommerce platform, or digital service falls under scope, the question is not whether you need evidence of compliance but what kind.
| Evidence Type | What It Demonstrates |
|---|---|
| EU Declaration of Conformity (Products) | Required for products under Article 16, declaring the product meets the accessibility requirements of the Directive |
| Technical Documentation (Products) | Required under Annex IV, covering product design, manufacture, and operation, plus any harmonised standards applied |
| Annex V Service Information | Required for services under Article 13, explaining in the general terms and conditions how the service meets accessibility requirements |
| Accessibility Audit Report | Documents how each page or screen was evaluated against WCAG 2.1 AA, the technical standard incorporated into EN 301 549, with identified issues and severity |
| ACR (VPAT INT Edition) | Maps product or service conformance to EN 301 549, commonly requested by EU procurement and enterprise buyers |
| Remediation Records | Shows a documented history of identified issues being addressed, tracked, and validated |
| Internal Accessibility Policy | Supports the ongoing procedures required by Article 13(3), covering roles, audit cadence, remediation tracking, and staff training |
Why Documentation Matters Under the EAA
The EAA is a Directive, which means each EU member state transposes it into national law. Enforcement varies by country, but Article 30 requires every member state to put penalties in place that are “effective, proportionate and dissuasive.” Across all member states, economic operators must be able to demonstrate compliance when asked.
Manufacturers, importers, distributors, and service providers each carry distinct obligations under Articles 7, 9, 10, and 13 respectively. When a market surveillance authority sends a reasoned request, you need to produce documentation in a language the authority can easily understand. Cooperation with the request is itself an obligation under the EAA. Article 22 lists missing or incomplete technical documentation as a form of non-compliance on its own. Having no documentation is a compliance issue, regardless of how accessible your product or service actually is.
What Does an Accessibility Audit Report Prove?
An accessibility audit report is evidence that your digital asset has been thoroughly evaluated. It documents how an auditor evaluated your digital product against a given technical standard and identifies every issue with its location, description, and relevant success criterion.
An accessibility audit (manual) is the only way to determine WCAG conformance. Automated scans catch only a subset of issues and miss criteria requiring human judgment: alt text meaning, heading structure, and keyboard focus order. Scans support your documentation but cannot replace an audit. A qualified auditor covers the full standard, including criteria automated tools cannot evaluate.
Accessible.org audits are fully manual and map to WCAG 2.1 AA and WCAG 2.2 AA. WCAG 2.1 AA is the technical standard incorporated into the harmonised standard EN 301 549. The resulting report is usable as part of EAA documentation when the evaluation scope reflects the digital product or service under EAA scope.
Do You Need a VPAT or ACR for the EAA?
A VPAT is a template. An ACR is the completed document. For EAA purposes, the relevant edition is the VPAT INT (International) edition, which maps to EN 301 549.
While the EAA does not explicitly require a VPAT or ACR, EU procurement processes frequently request one. Enterprise buyers evaluating SaaS products, ecommerce platforms, or digital services expect an ACR as part of vendor assessment. If your product is sold to organizations within the EU, an ACR built on the INT edition is practical evidence that signals conformance to the EN 301 549 standard.
An ACR does not have a formal expiration date, but it should be updated after significant product changes. An outdated ACR with issues that no longer reflect your product’s current state can work against you.
Public-Facing Documentation and Accessibility Policies
The EAA prescribes specific public-facing documentation depending on what you offer. For products, manufacturers must draw up an EU declaration of conformity per Article 16 and Annex IV, affix the CE marking, and keep technical documentation available to market surveillance authorities.
For services, Annex V requires service providers to include information in the general terms and conditions explaining how the service meets the accessibility requirements. That information must describe the applicable requirements, cover the design and operation of the service, and remain available to the public in written and oral format for as long as the service is in operation.
This is not marketing copy. It is formal documentation that surveillance authorities and users rely on. Vague language without specifics is a red flag.
An internal accessibility policy supports this work. It documents your organization’s processes for maintaining conformance: who is responsible, how audits are scheduled, how issues are tracked and remediated, and what training staff receive. Article 13(3) requires service providers to keep procedures in place so that conformance is maintained when service characteristics change, when accessibility requirements change, or when the harmonised standards change. A policy demonstrates that accessibility is built into your operations rather than treated as a one-time effort.
Tracking Remediation as Ongoing Evidence
Fixing issues after an audit is expected. What matters for compliance evidence is showing you did it systematically. Remediation records that document which issues were identified, when they were addressed, and how fixes were validated create a timeline of good-faith effort.
Tools like Accessibility Tracker can help centralize audit reports and track issues through remediation. For organizations managing multiple digital products under EAA scope, a single view of each project’s conformance status simplifies responding to regulatory requests.
A clear, documented path from audit to conformance gives you the records needed to respond to a reasoned request from a competent authority under Articles 7, 9, 10, or 13.
How Should You Organize Your Evidence?
Keep your documentation centralized and current. At minimum, we recommend your EAA documentation include an accessibility audit report evaluating against WCAG 2.1 AA, which is the technical standard incorporated into the harmonised standard EN 301 549. For products, add the technical documentation per Annex IV, the EU declaration of conformity per Article 16, and the CE marking. For services, add the Annex V information included in your general terms and conditions, kept available for the life of the service. Round this out with an ACR using the VPAT INT edition if your product is sold to EU organizations, remediation records showing issues tracked, fixed, and validated, and an internal accessibility policy covering roles, processes, and training.
Each document serves a different audience. The Annex V service information and the EU declaration of conformity are for the public and surveillance authorities. The audit report and ACR are for procurement buyers and authorities. The policy and remediation records are for internal governance and, if requested, regulatory review.
Keep all documentation in a centralized location that you can easily access should a request be made.
Can automated scans serve as EAA compliance evidence?
Not as any substantial evidence of conformance. Scans flag only a portion of accessibility issues and cannot evaluate criteria that require human judgment, such as whether alt text is meaningful or whether focus order is logical. Scan results can supplement your documentation, but they cannot replace an audit as your primary evidence of conformance.
How often should you update your EAA compliance documentation?
After any significant product change, such as a redesign, new feature release, or platform migration. Even without major changes, reviewing your audit report and your Annex V service information or EU declaration of conformity annually is a reasonable cadence. The EAA expects ongoing conformance, not a static snapshot.
What happens if you cannot produce evidence when asked?
Market surveillance authorities in each EU member state have the power to request documentation and, if it is missing or insufficient, take corrective action. Penalties vary by country but can include fines, product restrictions, or removal from the market. The absence of documentation is treated as a compliance issue on its own.
EAA compliance is not a single document. It is a set of records that together tell the story of how your organization evaluated, remediated, and maintained the accessibility of its digital products. The organizations best positioned are those that treat documentation as part of the process rather than an afterthought.
Contact Accessible.org to get an accessibility audit and the documentation you need for EAA compliance.
