EAA FAQ Conformance Statements

Start with the legal posture of the thing being documented. A product statement should not replace the EU declaration of conformity: manufacturers must draw up technical documentation, carry out the Annex IV conformity assessment procedure, draw up an EU declaration of conformity when compliance is demonstrated, and keep the technical documentation and declaration for five years after placing the product on the market.

A service statement should be framed differently. Service providers must prepare the information described in Annex V, explain how the service meets the applicable accessibility requirements, make that information publicly available in written and oral format, including in an accessible manner, and keep it for as long as the service is in operation.

For either type, keep the public wording narrower than the evidence allows. Say exactly which product model, software version, service journey, website, mobile app, document set, support channel, or terminal is covered; which requirements were assessed; which standard or technical specification was applied in full or in part; what evidence supports the claim; and what remains out of scope or unresolved.

Use EN 301 549 and WCAG as scoped evidence, not as a blanket EAA certificate. The EAA creates a presumption of conformity only for products and services that conform to harmonised standards, or parts of standards, whose references have been published in the Official Journal of the European Union, and only so far as those standards cover the relevant EAA requirements.

EN 301 549 is broader than WCAG because it covers ICT products and services, including web content, non-web documents, software, hardware-related features, support services, and other ICT functions. WCAG evidence is useful for web content and related software/document requirements, but it does not by itself prove that a payment terminal, e-reader, banking workflow, e-commerce service, support process, or product documentation satisfies every EAA requirement.

A good statement therefore names the exact EN 301 549 version, clauses or test basis used, the WCAG level or success criteria where relevant, the parts not assessed, and any EAA requirements handled outside the web or software test.

The evidence pack should let a market-surveillance authority, service compliance reviewer, customer, procurement team, or support lead understand what was assessed and why the claim is limited the way it is. Keep public wording, technical files and service operating records aligned so the statement does not promise more than the underlying evidence shows.

For products, Annex IV requires technical documentation that makes it possible to assess conformity with the relevant accessibility requirements and, where Article 14 is relied on, to show why the requirement would cause a fundamental alteration or disproportionate burden. For services, Annex V information may rely on harmonised standards or technical specifications in full or in part.

Most poor EAA conformance statements fail because they are too broad. They describe an accessibility ambition instead of a tested product or service boundary, or they reuse a WCAG accessibility-statement template for EAA product and service obligations that need different records.

The safer pattern is to write the narrowest truthful statement, keep the evidence matrix behind it, and update it when the product, service, standard, supplier, accessibility requirement, or known issue changes.