FAQEU

EAA FAQ Authority Response

The EU Accessibility Act sets accessibility requirements for selected consumer products and services, including e-commerce, banking, transport, electronic communications, e-books, and self-service terminals.

Use this FAQ to prepare a grounded answer when a product market surveillance authority or service compliance authority asks for EAA evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

How should teams respond to an EU Accessibility Act authority request? First identify whether the request concerns a product, a service, or both. Product market surveillance authorities can check conformity assessments, Article 14 fundamental-alteration or disproportionate-burden assessments, and technical documentation. Authorities responsible for services must check service compliance, follow up complaints or reports, and verify corrective action. Answer with the specific product or service record, not a generic accessibility policy.

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4 of 4 questions
Question 1

Separate product checks from service checks

For products, prepare the file a market surveillance authority would need to evaluate the product against the EAA: product identification, role in the supply chain, applicable accessibility requirements, conformity assessment, EU declaration of conformity where relevant, CE-marking evidence where relevant, technical documentation, and any Article 14 assessment relied on.

For services, prepare the information required to assess service compliance: the covered service, the accessibility requirements applied, the information made available to users about how the service meets those requirements, complaint or report handling, corrective action status, and the authority contact owner.

  • Route product requests to the owner of the technical file, conformity assessment, EU declaration of conformity, and accessibility test evidence.
  • Route service requests to the owner of the service description, user-facing accessibility information, support process, complaint log, and remediation plan.
  • If the same journey includes a product and a service, answer both parts separately so the authority can see which evidence belongs to which obligation.
Citations
Question 2

Prepare the evidence authorities can actually review

The response should show the authority how the conclusion was reached. For products, keep the technical documentation complete enough to identify the product, the applied requirements, the conformity assessment route, the standards or technical specifications used, and the test or design evidence supporting the declaration.

For services, keep the current service information in an accessible format or equivalent document. The record should explain how the service meets the applicable requirements and how users, complaints, incidents, or authority findings lead to corrective action.

  • Keep product technical documentation, conformity assessment evidence, EU declaration of conformity, CE-marking evidence where relevant, supplier evidence, and test results together.
  • Keep service accessibility information, terms or equivalent service document, support-process evidence, complaint or report log, remediation tickets, and release evidence together.
  • Map accessibility claims to Annex I requirements and, where used, harmonised standards or technical specifications instead of relying on broad labels such as accessible by design.
Citations
Recommended next step

Use this EAA guide as a cited evidence workflow

Turn this EU Accessibility Act page into a repeatable workflow for product, legal, quality, procurement, support, and engineering teams. Keep citations, owners, evidence, and review triggers together.

Question 3

Handle Article 14 assessments carefully

Article 14 is not a shortcut for missing evidence. If an economic operator relies on fundamental alteration or disproportionate burden, the response should include the documented assessment, the criteria applied, the result, and the accessibility requirements still implemented to the extent required.

Authorities can review whether the Article 14 assessment was carried out and whether its results were used correctly. Service providers also need to renew the assessment when requested by the service authority and at least every five years.

  • State whether Article 14 is being used for a specific product, service, feature, element, or function.
  • Attach the documented assessment and supporting evidence for fundamental alteration or disproportionate burden.
  • Show what accessibility requirements remain implemented and what remediation remains open.
  • Do not claim disproportionate burden based only on lack of priority, time, or knowledge.
Citations
Question 4

Respond to corrective action without inventing penalties

If an authority identifies non-compliance, the response should focus on the corrective action the EAA framework actually describes: what is non-compliant, which requirement is affected, what action will bring the product or service into compliance, who owns it, and how completion will be evidenced.

For products, market surveillance authorities can require corrective action and, if adequate action is not taken, can move toward restrictive measures such as withdrawal from the market. For services, Member State procedures must verify that the service provider has taken necessary corrective action. National penalties should be handled by country-specific counsel or verified national implementing law, not guessed in an FAQ response.

  • Acknowledge the authority request and preserve the request, response deadline, product or service scope, and named contact.
  • Send only evidence that matches the requested product, service, version, market, and requirement.
  • Track corrective action by requirement, owner, release or process change, verification evidence, and authority correspondence.
  • Avoid stating EU-wide fine amounts, penalty bands, or enforcement deadlines unless the verified national law for the relevant Member State supports them.
Citations
Primary sources

References and citations

accessible-eu-centre.ec.europa.eu
Referenced sections
  • AccessibleEU guidance source used for implementation context on Article 14 assessments, authority checks, and corrective action.
"guidelines for implementing accessibility"
eur-lex.europa.eu
Referenced sections
  • Articles 20, 22, 23, and 30 support corrective-action handling, withdrawal or restrictions for unresolved product non-compliance, service corrective-action verification, and Member State penalty rules.
"corrective action"
etsi.org
Referenced sections
  • ETSI overview for EN 301 549, the ICT accessibility standard used to organize evidence for many web, software, document, support, and ICT functions.
"Accessibility requirements"
single-market-economy.ec.europa.eu
Referenced sections
  • Commission overview for how harmonised standards support presumption-of-conformity analysis when their references are published for the relevant requirements.
"Harmonised standards"
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