European Accessibility Act EN 301 549 evidence matrix workflow

Create one matrix row for each covered product, service, feature, or supplier component. The first row should answer whether the item is one of the EAA product or service categories, which economic operator or service provider owns it, and which accessibility requirement or service information duty is being evidenced.

Do not start by pasting WCAG or EN 301 549 results into a spreadsheet. A test result is useful only after the record explains whether the EAA applies, which user-facing function is in scope, and whether the evidence is for a product conformity file, a service conformity explanation, procurement assurance, or remediation.

For ICT products and services, the examples here use EN 301 549 V3.2.1 as a clause-by-clause evidence structure. Each row should record the clause, any applicable precondition, the user-facing function, the applicable requirement, and the result. Except for clause 12, the requirements are self-scoping, so a row that is not applicable should explain the failed precondition instead of being deleted.

A practical matrix separates functional performance from technical tests. Clause 4 describes user needs; clauses 5 to 13 contain specific technical criteria; Annex B connects requirements to functional performance statements; Annex C gives the means to determine conformance for individual requirements but does not provide a complete testing methodology. Record sampling, environments, assistive technologies, and retest rules separately.

Treat the matrix as a release and audit record, not a checklist of accessibility slogans. Every applicable row should identify the evidence file, the tester or reviewer, the finding, the defect or remediation record, and the owner who accepted the result.

For products, link the matrix to the technical documentation and EU declaration workstream where relevant. For services, link it to the public or customer-facing information that explains how the service meets the applicable accessibility requirements, and keep the record current when the service, requirement, harmonised standard, or technical specification changes.

The matrix should make standards reliance explicit. Under the EAA, conformity with harmonised standards or parts of standards creates a presumption of conformity only to the extent the cited standards cover the relevant accessibility requirements and their references have been published in the Official Journal of the European Union. A draft, a procurement requirement, or a reference harmonised for another directive does not by itself create that EAA presumption.

Do not write 'EN 301 549 compliant' as the only conclusion. Record which version, clause, precondition, test result, and EAA requirement are being relied on. Also record what the standard evidence does not cover, such as legal scope, market role, service information duties, national implementation assumptions, or an Article 14 fundamental alteration or disproportionate burden assessment.