TemplateEU

EU Accessibility Act Accessibility Conformance Statement Template

Create a statement that explains what product or service was assessed, which Directive (EU) 2019/882 requirements apply, which standards or tests were used, and how users can get accessibility support.

This template separates product technical documentation, service information under , Annex I requirement mapping, exceptions, support routes, and evidence records so teams do not overclaim conformance.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

This is a drafting template, not an official EU form and not a substitute for the Directive's required records. Use a public or customer-facing conformance statement to identify the assessed product or service, the applicable Annex I requirements, the standards or technical specifications applied, the evidence and limitations, and the route for accessibility support. Products still need the applicable technical documentation and EU declaration of conformity; services still need the information and procedures required by Article 13 and .

Section 1

Statement header and scope fields

Start the statement with enough identification data for a customer, procurement reviewer, or authority to understand the assessed item without asking the project team for background. Separate products from services because the Directive uses different evidence structures: product technical documentation and EU declarations of conformity for products, and service information for services.

Use plain identification details such as the product model or service name, version, release, platform, geography, language coverage, consumer-facing channels, and the date the statement was last updated. State the EAA role, the applicable product or service category, and the assessment basis so the scope is clear without any draft placeholders.

  • Record owner: accountable business owner, accessibility lead, legal or regulatory reviewer, support owner, and evidence repository owner.
  • Scope identity: product model or service name, version, release, platform, geography, language coverage, consumer-facing channels, and whether a third-party or subcontracted component is included.
  • EAA role and category: manufacturer, importer, distributor, authorised representative, or service provider; then the product or service category assessed under Article 2.
  • Applicability date: product placement or service provision after 28 June 2025, plus any Article 32 contract, similar-service product, or self-service-terminal transition relied on and its end date.
  • Assessment basis: applicable Annex I sections, harmonised standards or technical specifications applied in full or in part, internal tests, user research, supplier declarations, and unresolved gaps.
  • Publication status: public statement, customer procurement statement, internal release gate, authority response pack, or product technical-file evidence.
Recommended next step

Turn the statement into a reviewable evidence pack

Use the template to align product, service, accessibility, support, procurement, legal, and release teams on the exact EAA claims the evidence can support.

Section 2

Service information and support route wording

For services, put the explanation in the general terms and conditions or an equivalent document. Make it publicly available in written and oral formats, including formats accessible to persons with disabilities, and keep it available for as long as the service operates.

Use wording that names the support channel and explains that users can request accessibility information and compatibility details in accessible modes of communication. Keep the description specific to the live support routes that are actually available.

  • General service description: what the service does, which user journeys are covered, and which user-facing channels are included.
  • Operation explanation: how users access, identify themselves, pay, receive content, complete transactions, or use transport, banking, e-book, audiovisual, electronic communications, or e-commerce functions where relevant.
  • Accessibility explanation: how the relevant Annex I requirements are met, including perceivable, operable, understandable, and robust web or mobile interfaces where those channels are in scope.
  • Support routes: help desk, call centre, technical support, relay service, training service, complaint intake, procurement contact, and escalation owner where those channels exist.
  • Maintenance statement: how changes in service characteristics, applicable accessibility requirements, harmonised standards, or technical specifications are reviewed before the statement remains current.
Section 3

Copy-ready scope and service-information fields

Replace each bracketed field with verified facts. Use the product header for a product summary and the service fields for Article 13 and information. A product summary does not replace the EU declaration of conformity.

  • Scope: [Product model or service name]; [version or release]; [operator and role]; [markets and languages]; [channels and journeys covered]; [assessment date].
  • Service description: [What the service does]; [who uses it]; [how a consumer accesses and completes each covered journey].
  • Accessibility explanation: [Applicable Annex I requirement]; [feature or process that meets it]; [standard edition and clause, if used]; [test or operating evidence].
  • Limitations: [Affected feature and requirement]; [known defect or scope exclusion]; [accessible alternative where provided]; [remediation owner and target]; [Article 14 assessment reference if relied on].
  • Support: [Public contact route]; [available accessible communication modes]; [how to request accessibility or assistive-technology compatibility information]; [escalation route].
  • Maintenance: [Accountable owner]; [service monitoring procedure]; [last evidence review]; [changes that trigger an update]; [next planned review].
Section 4

Annex I requirement mapping table

The useful part of the statement is the mapping table. It should connect each applicable Annex I requirement to the tested feature, standard clause, evidence record, result, owner, and limitation. Avoid a single blanket sentence that says the whole product or service is compliant unless the evidence actually supports every applicable requirement.

Template table columns: requirement source; applicable product or service feature; standard or technical specification used; test method; result; evidence link or record ID; known limitation; owner; next review trigger.

  • Product information row: labels, instructions, warnings, accessibility features, activation steps, user interface description, assistive-device interoperability, and accessible formats.
  • Product interface row: alternatives to vision, hearing, speech, colour, biometrics, fine motor control, time limits, and modes that could trigger photosensitive seizures.
  • Service information row: service functioning, product links, accessibility characteristics, assistive-device interoperability, electronic information, and accessible web or mobile channels.
  • Specific service row: electronic communications, audiovisual media access, passenger transport information, consumer banking, e-books, or e-commerce functions only where the service actually provides them.
  • Support row: available help desk, technical support, call centre, relay service, or training service routes and how they communicate accessibility and compatibility information.
Section 5

Product documentation and standards used

If the statement covers a product, keep it aligned with the product technical documentation and EU declaration of conformity rather than treating it as a standalone promise. The statement can summarise the assessment, but the evidence file should show the general product description, applied standards or technical specifications, and any design, manufacture, operation, or Article 14 material needed to assess conformity.

Use a short factual summary that lists the standards or technical specifications used, whether they were applied in full or in part, and any solutions adopted where they were not applied. That gives readers a complete but concise view of the product evidence.

  • List the harmonised standards or technical specifications used, but do not imply presumption of conformity unless the cited references cover the relevant requirements.
  • State whether each standard was applied in full, in part, or only as test guidance; include the clauses or requirement groups used.
  • Keep EU declaration of conformity references separate from service conformance statements because Article 16 applies to products.
  • If Article 14 was used for a product, the EU declaration of conformity must identify which accessibility requirements are subject to the exception.
  • Keep supplier declarations, third-party component evidence, assistive-technology compatibility tests, remediation records, and release approvals with the statement evidence pack.
Section 6

Exceptions, limitations, and what not to overclaim

Do not use the statement to hide unresolved accessibility defects. Use limitation language only when the limitation is backed by evidence, a documented remediation plan, or a valid Article 14 assessment for fundamental alteration or disproportionate burden.

Use direct language that separates confirmed limitations from general scope. Make clear that a limitation is a specific, documented condition rather than a broad excuse for non-compliance.

  • Do not claim full EAA conformance when only web pages, only WCAG-related checks, or only one platform was tested.
  • Do not cite EN 301 549 or WCAG as a complete EAA answer unless the mapped clauses cover the product or service requirement being claimed.
  • Do not use lack of time, priority, or accessibility knowledge as a limitation rationale.
  • Do not present a disproportionate-burden or fundamental-alteration claim without the documented assessment, retained results, and authority notification where the Directive requires it.
  • Do not claim that a microenterprise exemption, Member State implementation detail, or transitional rule applies unless the fact pattern and source are recorded.
Section 7

Evidence records to keep with the statement

The statement must point to reviewable records. Keep enough evidence to show what was assessed, who approved the conclusion, what standards or requirements were used, what defects remain, and how the statement will be updated when the service, product, requirements, or standards change. A statement date without version and scope data does not show that a later release was assessed.

Evidence register fields: record ID; product or service scope; Annex I requirement; standard clause or test criterion; test date; tester; result; defect or limitation; remediation owner; support workaround; approval; next review trigger.

  • For services: service description, operation explanation, Annex I mapping, service monitoring procedure, support-channel scripts, complaint records, and corrective-action records.
  • For products: technical documentation, applied standards list, test reports, assistive-technology compatibility records, EU declaration of conformity, supplier evidence, and CE marking release approval where relevant.
  • For Article 14 reliance: assessment, cost and benefit inputs, funding analysis, retained results, authority notification record where required, and five-year service reassessment tracking.
  • For standards: OJEU reference check, EN 301 549 or other clause mapping, whether the standard was applied in full or in part, and gap rationale where no harmonised standard or technical specification was applied.
  • For support: public contact route, accessible communication modes, escalation procedure, response templates, and training evidence for teams that answer accessibility questions.
  • For review timing: update the statement when the assessed release, consumer journey, supplier component, applicable requirement, cited standard, test result, limitation, Article 14 position, or support route changes.
Primary sources

References and citations

eur-lex.europa.eu7 citations
Referenced sections
  • Primary legal source for EAA scope, Annex I accessibility requirements, service-provider information duties, Article 14 limitations, product technical documentation, EU declarations of conformity, and compliance checks.
  • Supports the need to identify whether the statement covers a product or a service and to map the record to the Directive's product, service, economic-operator, and conformity provisions.
  • Article 13 and Annex V require public written and oral service information explaining conformity, retention while the service operates, and continued-conformity procedures; Annex I covers accessibility and assistive-technology information from available support services.
Show 4 more
  • Annex I is the binding source for product information, product interfaces, service information, web and mobile service accessibility, support services, and sector-specific service requirements.
  • Annex IV describes product technical documentation and requires lists of applied harmonised standards or technical specifications where relevant.
  • Article 14 defines when accessibility requirements do not apply because of fundamental alteration or disproportionate burden and requires documented assessment results in the stated cases.
  • Supports the evidence register by requiring service information, product technical documentation, authority cooperation, and retained Article 14 assessment results.
"accessibility requirements for products and services"
More quoted passages
"for as long as the service is in operation"
"ACCESSIBILITY REQUIREMENTS FOR PRODUCTS AND SERVICES"
"The technical documentation shall"
"fundamental alteration or impose a disproportionate burden"
"provide it with all information necessary"
accessible-eu-centre.ec.europa.eu3 citations
Referenced sections
  • Official AccessibleEU source for implementation materials covering accessibility in places, products, services, legislation, regulation, and standards.
  • Official AccessibleEU source showing that its support materials cover accessibility legislation, regulation, standards, products, and services.
  • Official AccessibleEU source for implementation-oriented accessibility legislation and standards materials that can supplement legal source review.
"guidelines for implementing accessibility"
More quoted passages
"accessibility legislation, regulation and standards"
etsi.org3 citations
Referenced sections
  • Official ETSI source for EN 301 549 as the ICT accessibility requirements standard relevant to clause-level conformance evidence.
  • Identifies EN 301 549 as the European standard for ICT accessibility requirements and explains its use for ICT products and services.
  • Supports clause-level ICT accessibility evidence because EN 301 549 covers web pages, mobile applications, desktop software, hardware, and combined ICT products and services.
"Accessibility requirements for ICT products and services"
More quoted passages
"web pages, mobile applications, desktop applications"
single-market-economy.ec.europa.eu3 citations
Referenced sections
  • Commission source for harmonised standards, OJEU references, and the limited compliance effect of standards only where they cover the relevant legal requirements.
  • Explains that harmonised standards can be used to demonstrate compliance when their references are published in the Official Journal and the relevant requirements are covered.
  • Grounds the statement's caution that harmonised standards are useful only to the extent they cover the relevant legal requirements and have the required OJEU reference status.
"demonstrate that products, services, or processes comply"
More quoted passages
"References of harmonised standards"
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