EU Accessibility Act Checklist

Start with the Article 2 scope table, not with a generic accessibility label. For products, check whether the item is one of the covered consumer ICT products or terminals placed on the EU market after 28 June 2025. For services, check whether the service is one of the covered consumer services provided after 28 June 2025.

Record the exact product model, software version, service journey, EU market, and consumer-facing function assessed. If the feature is only a back-office tool or a business-to-business support process, keep the reason it was excluded from the EAA checklist separate from the evidence for covered consumer journeys.

The checklist should name the legal role before assigning tasks. Article 3 defines manufacturer, authorised representative, importer, distributor, service provider, and economic operator. Articles 7 to 13 then attach different obligations to those roles.

Do not treat a reseller, marketplace, software publisher, service provider, or internal product team as interchangeable. If an importer or distributor places a product on the market under its own name or modifies it in a way that may affect compliance, Article 11 makes the manufacturer obligations relevant to that operator.

Use Annex I as the checklist spine. The evidence should show which Section I, II, III, IV, or V requirements apply and how each was tested, implemented, or found not applicable. A generic WCAG report is not enough unless it is mapped to the EAA service, product, feature, or journey being released.

Where ICT standards are used, cite them as evidence aids rather than as a blanket substitute for the Directive. Article 15 gives a presumption of conformity only for harmonised standards or technical specifications whose references have been published in the Official Journal and only to the extent that they cover the relevant EAA requirements.

For covered products, Annex IV requires technical documentation that makes it possible to assess conformity with the relevant accessibility requirements. The file should identify the applicable requirements, the design, manufacture, and operation of the product, the standards or technical specifications applied, and any alternative solutions used where those standards were not applied.

For covered services, Annex V requires public information in the general terms and conditions or an equivalent document. That information should describe the service, explain how it operates, describe how relevant Annex I requirements are met, and show that the delivery process and monitoring keep the service aligned with the Directive.

Article 14 is not a general waiver. It applies only where compliance would fundamentally alter the basic nature of the product or service or impose a disproportionate burden on the economic operator. The assessment must be documented and retained, except for the Directive's specific microenterprise product documentation carve-out.

Supplier and procurement evidence should be linked to the applicable role and requirement. A supplier declaration, accessibility statement, design note, or test report is useful only when it names the product, service, version, Annex I requirement, applied standard or technical specification, and change history it supports.

Before release, the checklist should block shipment or launch if the scope row, role assignment, Annex I map, evidence file, public service information, Article 14 record, or supplier evidence is missing for an in-scope item. For products, changes in design, characteristics, harmonised standards, or technical specifications must be taken into account for series production. For services, changes in service characteristics, accessibility requirements, harmonised standards, or technical specifications must be reflected in procedures.

After launch, monitoring should track accessibility complaints, non-conformities, corrective actions, supplier changes, standards changes, and authority requests. Articles 19 to 23 describe product market surveillance, safeguards, formal non-compliance, and service compliance checks, so the evidence file should be ready for authority review rather than assembled only after a request arrives.