The EAA conformity assessment process is the procedure economic operators follow to confirm a product or service meets the accessibility requirements of the European Accessibility Act before placing it on the EU market. For most digital products and services covered by the EAA, conformity is demonstrated through internal production control, where the operator prepares technical documentation, evaluates the product or service against the harmonized standard EN 301 549, and issues an EU Declaration of Conformity or an accessibility statement. The process is self-declared, but the documentation must be thorough enough to support that declaration if a market surveillance authority requests it.
| Element | Detail |
|---|---|
| Assessment type | Self-declared, internal production control (Module A) for most products and services |
| Reference standard | EN 301 549, which incorporates WCAG 2.1 AA for web content |
| Required output (products) | Technical documentation plus EU Declaration of Conformity |
| Required output (services) | Accessibility statement made available to the public |
| Enforcement | Market surveillance authorities in each EU member state |
| Effective date | June 28, 2025 |
Who needs to complete the assessment?
Any economic operator placing a covered product or service on the EU market must complete the assessment. That includes manufacturers, importers, distributors, and service providers.
Covered categories include ecommerce, banking services, e-books, transport ticketing, and consumer end-user equipment. If your product or service falls inside the EAA scope and is offered to consumers in the EU, the assessment applies regardless of where your company is based.
What does the assessment actually involve?
The EAA uses a self-declaration model. There is no notified body for most categories and no third-party certification. The operator is responsible for evaluating its own product or service and producing the documentation.
Practically, this means three things. First, mapping the product or service against the functional accessibility requirements in Annex I of the EAA. Second, evaluating conformance with EN 301 549, which is the harmonized European standard that creates a presumption of conformity. Third, recording the results in technical documentation that can be produced on request.
How EN 301 549 fits in
EN 301 549 is the technical backbone of the assessment. For web content and mobile apps, it points to WCAG 2.1 Level AA. For hardware, software, and documentation, it adds specific clauses covering inputs, outputs, biometrics, and assistive technology compatibility.
Conformance with EN 301 549 gives the operator a presumption of conformity with the EAA. You can deviate from the standard, but you then carry the burden of proving the product or service still meets the underlying functional requirements.
The role of an accessibility audit
An audit is how operators actually verify conformance with EN 301 549 in practice. A manual accessibility audit identifies the issues that an automated scan cannot detect, since scans only flag approximately 25% of issues.
For digital products and services, the audit report becomes a core piece of the technical documentation. It records what was evaluated, against which version of WCAG and EN 301 549, and what issues were identified. After remediation, a follow-up evaluation confirms the issues have been addressed.
Technical documentation requirements
Annex IV of the EAA outlines what the technical file must contain. The exact list varies for products versus services, but the core elements are consistent.
The technical file must include a general description of the product or service, a list of the harmonized standards applied (including EN 301 549), evaluation results such as audit reports and any records, a description of design and manufacturing where relevant, and justifications for any disproportionate burden or fundamental alteration claims.
Documentation must be kept for five years after the product is placed on the market or the service is last provided.
The EU Declaration of Conformity and accessibility statement
For products, the operator issues an EU Declaration of Conformity. This is a formal document stating that the product meets the accessibility requirements of the EAA. The CE marking is then affixed.
For services, the equivalent output is an accessibility statement. It must be made available to the public, written in clear language, and cover how the service meets the accessibility requirements, including any exceptions claimed.
What happens after the assessment?
The assessment is not a one-time event. Operators must monitor conformance over the life of the product or service, update documentation when significant changes occur, and respond to complaints or market surveillance inquiries.
If a market surveillance authority identifies an issue, the operator is expected to bring the product or service into conformity, withdraw it, or restrict its availability. Penalties for non-conformance are set at the member state level and vary considerably.
Frequently asked questions
Do I need a notified body to complete the EAA conformity assessment?
No. For the products and services covered by the EAA, conformity is self-declared through internal production control. The operator evaluates its own product or service and produces the technical documentation. Third-party certification is not required.
Is WCAG 2.1 AA enough for EAA conformity?
For web content and mobile apps, WCAG 2.1 AA is the operative standard within EN 301 549. For non-web software, hardware, and documentation, additional clauses of EN 301 549 apply. So WCAG 2.1 AA covers the web layer, but the broader product or service may need to map to other parts of the standard.
How long does the EAA conformity assessment process take?
It depends on the scope. A focused website audit can be completed in a few weeks. A full assessment covering hardware, software, documentation, and customer-facing services for a large operator can take several months, particularly when remediation cycles are included.
What happens if I claim disproportionate burden?
You can claim it, but you must document the assessment in writing, justify the conclusion against the criteria in Annex VI, and reassess at least every five years or when the service changes. Market surveillance authorities can review the justification, and a weak file can be rejected.
The EAA conformity assessment process is self-declared, but the documentation behind it has to hold up. A thorough audit against EN 301 549, clean records, and a public-facing statement are what separate a defensible file from one that collapses under review.
Need help preparing for EAA conformity? Contact Kris Rivenburgh.