EU Accessibility Act scope classifier workflow

Start with the Article 2 category, not with a generic accessibility checklist. For products, record whether the item is consumer general purpose computer hardware or its operating system, a payment terminal or other covered self-service terminal, consumer terminal equipment used for electronic communications, consumer terminal equipment used for audiovisual media services, or an e-reader.

For services, record whether the service is provided to consumers and falls into electronic communications, access to audiovisual media services, listed passenger transport service elements, consumer banking, e-books and dedicated software, or e-commerce. For urban, suburban, and regional transport services, Article 2 narrows the relevant transport elements to interactive self-service terminals.

Once a category is matched, classify the role. The Directive separates manufacturers, authorised representatives, importers, distributors, and service providers, and defines economic operator to include those roles. A company can move into manufacturer obligations if it places a product on the market under its own name or trademark, or modifies a product already placed on the market in a way that may affect compliance.

Use the role to assign the evidence owner. Product cases usually need a product owner for technical documentation, EU declaration of conformity, CE marking, traceability, and complaint or non-conformity records. Service cases usually need a service owner for the public accessibility information, service delivery controls, change controls, and authority response file.

Do not use exclusions as a shortcut before the Article 2 match is recorded. For websites and mobile applications, Article 2 excludes specific content types: pre-recorded time-based media and office file formats published before 28 June 2025, certain online maps where essential navigational information is accessible digitally, third-party content outside the economic operator's funding, development, or control, and archives that are not updated or edited after 28 June 2025.

Microenterprise treatment depends on the fact pattern. Article 4 exempts microenterprises providing services from the service accessibility requirements and related obligations. Article 14 treats microenterprises dealing with products differently: they are exempt from documenting the Article 14 assessment, but if they rely on Article 14 and an authority requests it, they must provide the facts relevant to the assessment.

Use Article 14 only when compliance would require a fundamental alteration of the product or service's basic nature or impose a disproportionate burden. The record must show the assessment against Annex VI criteria; for service providers relying on disproportionate burden, renew the assessment when the service changes, when the authority requests it, and at least every five years.

The final output should let a release reviewer or authority see why the EAA path was selected. Separate 'in scope', 'out of scope', 'excluded content', 'service microenterprise exemption', and 'Article 14 exception used' outcomes so later teams do not confuse a scope answer with a conformity answer.

For products, link the scope decision to the Annex IV technical documentation file, applied harmonised standards or technical specifications, conformity assessment output, EU declaration of conformity, CE marking decision, and product identification records. For services, link it to the Annex V accessibility information in the terms and conditions or equivalent document, the description of how applicable Annex I requirements are met, and the service delivery monitoring evidence.