EU Accessibility Act Compliance

Start with Article 2 and Article 4, not with a generic accessibility statement. The EAA applies to listed products placed on the market after 28 June 2025 and listed services provided to consumers after that date, subject to Article 32 transitions. It then points those products and services to the applicable sections of Annex I. Because the EAA is a directive, the operating record should also identify the national transposing law and competent authority in every affected Member State.

The operating model should separate product-chain duties from service-provider duties. Manufacturers, authorised representatives, importers, and distributors have different product obligations under Articles 7 to 12. Service providers have a separate duty under Article 13 to design and provide services in accordance with the applicable accessibility requirements and to keep public information explaining how the service meets them.

Organise the compliance file by Annex I. For products, Section I covers accessible information, user interface and functionality design, and support-service information; Section II adds accessible packaging and instructions for covered products other than self-service terminals.

For services, Section III requires accessible information about the service, products used in the service, websites, mobile applications, electronic information, and support services. Section IV adds service-specific requirements for electronic communications, audiovisual media access services, passenger transport information, urban and regional transport self-service terminals, consumer banking, e-books, and e-commerce.

For covered products, the EAA uses an internal production control conformity assessment procedure in Annex IV. The manufacturer must establish technical documentation that is sufficient to assess conformity with the relevant accessibility requirements and, where Article 14 is used, to show the claimed fundamental alteration or disproportionate burden.

CE marking belongs in the product file, not the service file. When the Annex IV procedure demonstrates product conformity, the manufacturer draws up the EU declaration of conformity and affixes the CE marking to the product, data plate, packaging, or accompanying documents as Article 18 allows.

For covered services, Article 13 and Annex V require a different evidence model. The service provider prepares information explaining how the service meets the applicable accessibility requirements, makes that information public in written and oral format and in an accessible manner, and keeps it for as long as the service is in operation.

The service compliance file should also show that service delivery and monitoring keep the service aligned when service characteristics, applicable accessibility requirements, harmonised standards, or technical specifications change.

Article 15 gives harmonised standards and technical specifications their role: they create a presumption of conformity only for the requirements they cover and only when the references have the required legal status. A compliance file therefore needs a standards register, not a blanket statement that a product or service is accessible.

When EN 301 549 or another accessibility standard is used, record the version, clauses applied, EAA Annex I requirements covered, test method, result, exceptions, and any gaps handled by design descriptions, user research, assistive-technology testing, or supplier evidence.

Article 14 limits only the requirements that would fundamentally alter the basic nature of the product or service or impose a disproportionate burden on the economic operator. The assessment must be carried out, documented, retained, and provided to authorities on request. Microenterprises dealing with products need not document the assessment but must provide the relevant facts if an authority asks.

A corrective-action process should connect complaints, audit findings, authority requests, product non-conformity, service non-conformity, supplier changes, and standard updates to concrete remediation records.

The compliance file should be organised so a product reviewer, service owner, procurement team, support lead, or competent authority can trace every conclusion from scope through design, testing, release, monitoring, and remediation.

Keep records versioned by product model, software release, service journey, market, and operator role. A single accessibility test result is rarely enough unless it is tied to the exact Annex I requirement and the exact product or service state being released.

Assign a named owner and approval state to each record. The manufacturer owns the product conformity decision and declaration, product-chain operators perform their role-specific checks, and the service provider owns service design, public information, monitoring, correction, and authority reporting. Design, engineering, testing, procurement, and support teams supply evidence but do not replace those legal roles.