Under the European Accessibility Act, you need to keep technical documentation, accessibility statements, audit reports, remediation evidence, training records, and procurement files. These records show how your product or service meets the EAA’s accessibility requirements and must be available to market surveillance authorities on request. Most economic operators are expected to retain documentation for at least five years after a product is placed on the market or a service is provided. The format is flexible, but the content has to be clear, current, and tied to a specific product or service.
| Record Type | What It Covers |
|---|---|
| Technical documentation | Product or service description, accessibility requirements applied, and how each was met |
| Accessibility statement | Public-facing document describing how the service meets EAA requirements |
| Audit reports | WCAG 2.1 AA or EN 301 549 evaluation results, including issues identified |
| Remediation evidence | Records of fixes made, validation, and dates |
| EU Declaration of Conformity | Required for products covered by the EAA, signed by the manufacturer |
| Procurement and vendor files | Evidence that third-party components meet accessibility requirements |
| Training records | Documentation of staff training on accessibility obligations |
Why EAA Conformance Records Matter
The EAA went into effect on June 28, 2025. Member states enforce it through national authorities, and those authorities can request your documentation at any point. Without records, you cannot demonstrate conformance. Without evidence of conformance, you face penalties, market withdrawal, or service suspension.
Records are also how you protect yourself internally. They show what was evaluated, what was fixed, what was left, and why. That history matters when products are updated, when staff turns over, or when a complaint arrives.
Technical Documentation
This is the core of your EAA conformance records. The EAA requires technical documentation that describes the product or service and explains how it meets the accessibility requirements in Annex I.
For products, the documentation should include a general description, design and manufacturing drawings where relevant, the accessibility requirements that apply, and the standards or technical specifications used to meet them. For services, it should include the description of the service, the requirements that apply, and how the service provider meets them.
If you applied harmonized standards like EN 301 549, reference them. If you used another method to meet a requirement, document that approach and explain why it satisfies the requirement.
Accessibility Statement
Services covered by the EAA need a public accessibility statement. The statement explains how the service meets EAA accessibility requirements and gives users a way to report issues.
The statement is part of your records, but it also lives on your website where users and authorities can find it. Keep dated versions when you update it, so you have a history of what was said and when.
Audit Reports and Evaluation Evidence
An audit report is the document that identifies accessibility issues against a specific standard, usually WCAG 2.1 AA or EN 301 549. For EAA conformance, your audit report is the primary evidence that you evaluated your product or service against the right criteria.
Keep the full audit report, not a summary. The report should include the scope (pages, screens, or product views evaluated), the standard used, the issues identified, severity ratings, and recommendations. An automated scan is not an audit and cannot stand in for one. Scans only flag approximately 25% of issues, so a scan report alone does not show conformance.
What About Remediation and Validation Records?
After an audit identifies issues, you fix them. Records of those fixes matter as much as the audit itself.
For each issue, keep a record of what was changed, who made the change, when it was completed, and how it was verified. Validation is the step where someone confirms the fix actually addresses the issue. That validation should be documented too, ideally with a follow-up review by an auditor.
If you use a project management platform to track issues, exports from that platform can serve as remediation records.
EU Declaration of Conformity
Manufacturers of products covered by the EAA must draw up an EU Declaration of Conformity. This is a formal document where the manufacturer states that the product meets the applicable accessibility requirements.
The declaration references the technical documentation, identifies the product, and is signed by the manufacturer or authorized representative. It must be kept for ten years after the product is placed on the market.
Procurement and Vendor Documentation
If your product or service uses third-party components, you are still responsible for the accessibility of the final result. Keep records that show you evaluated vendor accessibility, including any VPATs or ACRs received from suppliers.
This is especially relevant for SaaS companies, ecommerce platforms, and any service that integrates external tools. A vendor’s ACR does not transfer conformance to you, but it shows you did due diligence on the components you use.
Training Records
The EAA expects economic operators to have staff who understand the accessibility requirements that apply to their work. Training records document what was taught, who attended, and when.
These do not need to be elaborate. A roster, the training material, and the date are enough. The point is to show that accessibility is part of how the organization operates, not a one-time project.
How Long Should You Keep EAA Conformance Records?
For products, the EU Declaration of Conformity and technical documentation must be retained for ten years after the product is placed on the market. For services, most economic operators are expected to retain records for at least five years after the service is provided, though specific member state rules can extend this.
The safest approach is to keep records for as long as the product or service is in use, plus a buffer after it is withdrawn.
FAQs
Do I need EAA conformance records if my product is already accessible?
Yes. Accessibility alone is not enough under the EAA. You need documentation that shows how you confirmed conformance. Without records, an authority cannot verify your claim, and you cannot defend it.
Can I use a VPAT or ACR as my EAA conformance record?
An ACR is useful supporting evidence, especially for software and digital services, but it does not replace the full technical documentation required by the EAA. The ACR shows conformance to WCAG or EN 301 549; the EAA technical file ties that evidence to the specific accessibility requirements in Annex I.
Who can request to see my EAA conformance records?
Market surveillance authorities in EU member states can request your records. The specific authority depends on the country and the type of product or service. Requests can also come during procurement or as part of a complaint investigation.
What happens if my records are incomplete?
Incomplete records put you in the same position as having no records. Authorities can issue corrective orders, fines, or restrict your product or service from the market. Penalties vary by member state.
EAA conformance is built on evidence, and evidence is built on records. If you have not started a documentation file for each covered product or service, that is the place to begin.
For help building out your EAA conformance documentation, Contact Kris.