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 V, Annex I requirement mapping, exceptions, support routes, and evidence records so teams do not overclaim conformance.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

An EU Accessibility Act conformance statement should be a controlled public or customer-facing record, not a marketing claim. Use it to say exactly what is in scope, which Annex I product or service requirements were assessed, which harmonised standards or technical specifications were applied, what evidence supports the conclusion, and where users can request accessible support or report an accessibility issue.

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 Annex V 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.
  • 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, the statement should include the Annex V information that explains how the service meets the applicable accessibility requirements. Put this information where users already look for service terms or support, and make it available in accessible written and oral formats.

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

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 4

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 should 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 5

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 6

Evidence records to keep with the statement

The statement is only useful if it points 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.

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: Annex V 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.
Primary sources

References and citations

accessible-eu-centre.ec.europa.eu
Referenced sections
  • Official AccessibleEU source for implementation-oriented accessibility legislation and standards materials that can supplement legal source review.
"accessibility legislation, regulation and standards"
etsi.org
Referenced sections
  • Supports clause-level ICT accessibility evidence because EN 301 549 covers web pages, mobile applications, desktop software, hardware, and combined ICT products and services.
"web pages, mobile applications, desktop applications"
single-market-economy.ec.europa.eu
Referenced sections
  • 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.
"References of harmonised standards"
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