EU Accessibility Act Applicability Test

Start with category, not with technology. Ask whether the offering is one of the listed products or services. Covered products include consumer general purpose computer hardware and operating systems, specified self service terminals, consumer terminal equipment used for electronic communications services, consumer terminal equipment used for audiovisual media services, and e-readers. Covered services include electronic communications services, services providing access to audiovisual media services, defined elements of passenger transport services, consumer banking services, and e-commerce services.

Then identify role. A manufacturer, importer, distributor, and service provider do not carry the same obligations or evidence burden. Product roles trigger technical documentation, conformity assessment, EU declaration of conformity, and CE related workflows. Service providers need operating controls, accessible information, and a defensible service evidence pack.

The output should be more than a yes or no answer. Build a scope register that names each offering, the exact in-scope category, role, channels, applicable requirements set, evidence owner, and next review trigger. This stops teams from re-debating scope every quarter.

Attach a short decision memo that records what was considered, what was excluded, what transitional allowance was used if any, and which documents prove the conclusion. That memo becomes the anchor for procurement responses, release gating, and market surveillance readiness.