EU Accessibility Act Testing and Conformance Evidence

Annex I is the anchor for EAA accessibility evidence. A useful matrix separates product requirements, service requirements, sector-specific requirements, support-service information, and functional performance criteria so reviewers can see which requirements were applicable, tested, not applicable, or handled through an Article 14 assessment.

For products, capture evidence for accessible instructions and warnings, user interface and functionality design, assistive-technology interoperability, packaging or maintenance instructions where relevant, and available support services. For services, capture evidence for accessible service information, websites, online applications, mobile services, support services, and any sector-specific functions such as banking identification and payments, e-book metadata, or e-commerce checkout.

Product evidence and service evidence are not the same file. For products, Annex IV requires technical documentation that lets conformity with the relevant accessibility requirements be assessed. It should cover the applicable requirements and, as relevant, the design, manufacture, and operation of the product.

For services, Annex V requires information in the general terms and conditions or an equivalent document explaining how the service meets the accessibility requirements. That service record should describe the service in accessible formats, explain its operation, describe how the relevant Annex I requirements are met, and show that the service delivery process and monitoring keep the service compliant.

The manufacturer owns the product conformity file and must keep the technical documentation and EU declaration of conformity for five years after the product is placed on the market. A service provider must keep its accessibility information for as long as the service operates. Importers and distributors still need enough product traceability and conformity evidence to perform their own checks and cooperate with an authority; a supplier report does not transfer the legal duty holder's responsibility.

EN 301 549 V3.2.1 is useful ICT accessibility evidence because it covers functional performance statements and technical requirements for web content, documents, software, hardware, support services, and related ICT features. It includes requirement-by-requirement means for determining conformance, but Annex C does not provide a testing methodology. V3.2.1 supports the Web Accessibility Directive. ETSI now publishes EN 301 549 V4.1.1 (2026-09). Publication of an edition does not by itself establish an EAA presumption of conformity; verify the relevant Official Journal citation and the requirements it covers.

Do not reduce the EAA record to WCAG pass/fail results. WCAG evidence is important for web, document, and software interfaces, but EAA Annex I also includes product information, packaging, assistive-technology interoperability, support services, sector-specific service functions, and functional performance criteria. The test plan should therefore say where WCAG or EN 301 549 applies and where another inspection, hardware test, service process check, or Article 14 assessment is needed.

Harmonised standards can help, but they do not erase the need for traceability. Article 15 gives a presumption of conformity only for harmonised standards or parts of standards whose references have been published in the Official Journal, and only insofar as those standards or parts cover the relevant EAA accessibility requirements.

If the team relies on Article 14 because a requirement would fundamentally alter the product or service or impose a disproportionate burden, the record needs more than a risk note. Article 14 requires an assessment, documentation of relevant results, retention for five years calculated from the last making available of a product or after a service was last provided, authority access on request, renewal rules for service providers relying on disproportionate burden, and information to the relevant authorities when the exception is used. Microenterprises are exempt from the Article 14(8) information duty, and microenterprises dealing with products have a separate documentation derogation.