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Covered services other than urban, suburban, and regional transport must satisfy the general service requirements in Annex I Section III unless a scoped exception applies. That means accessible products used in the service, accessible information about how the service works and how those products connect to assistive devices, accessible websites and mobile services, and accessible support information where support services are available. Article 4(3) excludes those three local transport categories from Section III but applies the relevant Section IV self-service-terminal requirement.

Annex I Section IV then adds service-specific duties. Electronic communications services must provide real-time text in addition to voice, total conversation where video is provided, and synchronised emergency communications transmission to the most appropriate public safety answering point where relevant.

Audiovisual media access services must provide accessible electronic programme guides and must transmit accessibility components such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles, and sign language interpretation with adequate quality, synchronisation, and user control.

Consumer banking services must make identification methods, electronic signatures, security, and payment services perceivable, operable, understandable, and robust. Banking information must be understandable without exceeding level B2 of the Council of Europe's Common European Framework of Reference for Languages.

Article 13 requires service providers to design and provide services in accordance with the EAA accessibility requirements, prepare information explaining how the services meet the applicable requirements, make that information publicly available in written and oral formats including accessible formats, and keep it for as long as the service operates.

Annex V explains what that service information should contain: a general description of the service in accessible formats, descriptions and explanations needed to understand service operation, and a description of how the relevant Annex I requirements are met. It also calls for information demonstrating that service delivery and monitoring keep the service compliant.

If a provider relies on fundamental alteration or disproportionate burden under Article 14, the assessment must be documented and retained. Service providers relying on disproportionate burden must renew the assessment when the service is altered, when requested by the authority responsible for checking services, and at least every five years.

Do not describe the EAA as covering every service offered by a bank, transport operator, telecommunications provider, media company, publisher, or online retailer. Check whether the specific consumer-facing service falls into Article 2 and the relevant Article 3 definition.

Do not treat audiovisual media content accessibility and access-service accessibility as the same rule. The EAA covers services providing access to audiovisual media services, including electronic programme guides, and Annex I focuses on transmitting accessibility components with adequate quality, synchronisation, and user control.

Do not assume every transport operation is fully in scope. Article 2 names specific transport service elements and separately limits urban, suburban, and regional transport to interactive self-service terminals.

Do not use harmonised standards as a substitute for the legal scope analysis. Standards can help evidence technical accessibility for ICT components, but the EAA service category and Annex I duty still need to be mapped.

The European Accessibility Act makes the applicable Annex I accessibility requirements the legal target for covered products and services. Article 15 creates a presumption of conformity where products or services conform with harmonised standards or parts whose references have been published in the Official Journal of the European Union, or with technical specifications or parts established by a Commission implementing act under Article 15, and only so far as those standards, technical specifications, or parts cover the relevant EAA requirements.

EN 301 549 is a practical ICT evidence bridge. ETSI describes it as a European standard for ICT products and services and says it applies to software, hardware, and combinations of hardware and software. EN 301 549 V3.2.1 is harmonised for the Web Accessibility Directive. ETSI published the final draft of V4.1.0 in June 2026 with EAA relationship tables, but a final draft is not an OJEU citation, so do not transfer either the Web Accessibility Directive reference or final-draft status into an EAA presumption claim.

EN 301 549 V3.2.1 reflects WCAG 2.1 content in clauses 9, 10, and 11 for web content, non-web documents, and software, and its Annex C explains how to determine conformance with individual requirements. Write a WCAG report as evidence for those EN 301 549 requirements, not as a standalone EAA conclusion.

A useful WCAG evidence record lets a reviewer reconstruct what was tested and why it was relevant. Treat each record as a clause-level test artifact: identify the asset, the user journey or screen, the EN 301 549 requirement, the WCAG success criterion where applicable, the test method, the result, the defect, and the fix.

For products, the EAA technical documentation must make it possible to assess conformity with relevant accessibility requirements and list harmonised standards or technical specifications applied in full or in part. For services, the service provider must explain how the service meets the applicable accessibility requirements and keep that information for as long as the service is in operation. WCAG evidence should feed those records rather than replace them.

WCAG is not the same thing as EN 301 549, and EN 301 549 is not the whole EAA analysis. EN 301 549 includes functional performance statements and requirements beyond WCAG-derived web criteria, and the EAA includes legal duties about covered products and services, economic operators, conformity assessment, service information, corrective action, and cooperation with authorities.

Do not convert a clean WCAG test into unsupported claims such as 'EAA compliant', 'EN 301 549 compliant', or 'presumed compliant' unless the record shows the exact scope of the claim and the standards or technical specifications actually relied on. If the test covered only sampled pages, say that. If it covered only a checkout journey, say that. If documents, mobile app screens, hardware controls, support services, or procurement evidence were not tested, say that too.

Review this checklist before relying on a WCAG report in an EAA evidence pack. State what the test proves, what it does not prove, and what additional EAA or EN 301 549 evidence is still needed.

The product list is closed and category based. A product is not covered merely because it has software, a screen, a web portal, or an accessibility feature. Check whether it fits one of the Article 2 product categories and then identify the product-side economic operator: manufacturer, authorised representative, importer, or distributor.

Article 3 defines a product as a good produced through a manufacturing process, excluding food, feed, living plants and animals, products of human origin, and products of plants and animals relating directly to future reproduction. That definition matters when a connected offer combines hardware, software, and an online service.

For services, the EAA focuses on consumer-facing categories. Article 3 defines a service provider as a natural or legal person that provides a service on the Union market or offers to provide such a service to consumers in the Union. Article 2 lists answering emergency communications to 112 separately, and Article 31 allowed Member States to apply the national measures for that duty as late as 28 June 2027.

Article 3 defines a consumer as a natural person acting for purposes outside that person's trade, business, craft, or profession. The same platform or feature can therefore need separate conclusions for a consumer offer and a business-only offer; technology alone does not settle service scope.

The service category is not always the same as the underlying sector label. For transport, Article 2 covers specific digital and terminal elements of air, bus, rail, and waterborne passenger transport services, with a narrower rule for urban, suburban, and regional transport services.

Mixed offers need two checks. Hardware and operating systems are product-side items when they are placed on the market. Online journeys, banking, e-books, ticketing, media access, electronic communications, and e-commerce are service-side items when provided to consumers. The same commercial offer can therefore need both a product scope record and a service scope record.

Article 2 also limits some website and mobile application content. These limits do not remove an entire covered service from scope; they identify content types that the Directive says it does not apply to.

Keep evidence only for facts the scope conclusion actually depends on. A useful record should let a reviewer see the product or service facts, the Article 2 category, the Article 3 definition used, and the source relied on without reconstructing the project history.

Where a product or service is in scope, link the scope record to the accessibility requirements and evidence used for conformity work. Article 4 points covered products and services to Annex I accessibility requirements, while standards or technical specifications may be relevant when used to show how requirements are met.