What Documentation Do You Need for EAA Compliance?

EAA compliance requires you to keep documentation that shows how your product or service meets the accessibility requirements, and to record any assessment you rely on to limit those requirements. The European Accessibility Act (EAA) treats this paperwork as proof, not a formality. Without it, you cannot demonstrate that you met your obligations.

The EAA is Directive (EU) 2019/882, and it applies to products placed on the market and services provided to consumers after 28 June 2025. The deadline has passed, so the rules are in effect now.

EAA documentation at a glance

Document	What It Means for You
Assessment of conformity	A record showing your product or service meets the accessibility requirements in Annex I.
Disproportionate-burden assessment	Required only if you claim an exception; must be renewed at least every five years for services.
WCAG conformance records	Audit results and a VPAT or ACR that evidence how your digital assets meet WCAG 2.1 AA or 2.2 AA.

What documentation does the EAA actually require?

The core requirement is evidence. You need to show, on paper, that your product or service satisfies the accessibility requirements set out in the directive. The specific record depends on whether you are a manufacturer, importer, distributor, or service provider.

The EAA sets accessibility requirements in Annex I and gives illustrative examples in Annex II. Your documentation should map what you built to those requirements.

For websites, Annex II describes the target plainly. The directive lists as an example: “Providing text description of pictures, making all functionality available from a keyboard, giving users enough time to read, making content appear and operate in a predictable way, and providing compatibility with assistive technologies, so that persons with diverse disabilities can read and interact with a website.” (Annex II).

These records are the documentation that shows a service provider met the accessibility requirements:

• An assessment of how the product or service conforms to the Annex I requirements.
• Audit and evaluation results, including screen reader testing and keyboard testing findings.
• WCAG conformance evidence, typically a VPAT or the resulting ACR.
• Any disproportionate-burden assessment, where you rely on that exception.

What about the disproportionate-burden assessment?

The accessibility requirements apply only so far as they do not impose a disproportionate burden or force a fundamental alteration of the product or service. If you rely on that exception, the assessment behind it becomes part of your documentation.

The directive is strict about what does not count. It states: “Lack of priority, time or knowledge should not be considered to be legitimate reasons” for claiming a disproportionate burden.

Even when an exception applies, you must still apply the requirements that are not disproportionate. Service providers must renew the assessment at least every five years.

Do microenterprises have the same documentation obligations?

No. Microenterprises providing services are exempt from the accessibility requirements and the related obligations. Microenterprises dealing with products get lighter obligations and are exempt from documenting their assessment.

There is still one condition. A microenterprise dealing with products must supply the facts of its assessment to a market surveillance authority on request, even without keeping formal documentation.

How do you build and keep EAA documentation?

Documentation is not a one-time task. Products change, content is updated, and your evidence has to keep pace. Accessible.org recommends WCAG 2.1 AA or WCAG 2.2 AA as the technical standard for digital assets.

Building your EAA documentation follows a clear order:

1. Conduct an audit of your product or service against WCAG and the Annex I requirements.
2. Record the results in a VPAT and produce the resulting ACR.
3. Complete a disproportionate-burden assessment only if you plan to claim that exception.
4. Store everything and set a schedule for keeping records current, which is easier when you are tracking these documents over time.

An Accessibility Tracker platform helps track EAA compliance progress and keeps your audit history and conformance records in one place.

FAQ

Is a VPAT required for EAA compliance?

The directive does not name the VPAT format, but a VPAT and its resulting ACR are a practical way to document how your digital assets meet WCAG conformance.

How often must I update my documentation?

Keep conformance records current as your product or service changes. Service providers must renew any disproportionate-burden assessment at least every five years.

Does the EAA require WCAG conformance specifically?

The EAA states the accessibility requirements in Annex I. WCAG 2.1 AA or 2.2 AA is the widely used technical standard for meeting those requirements for digital assets.

Get Started

Do you need help with EAA compliance? Contact us to ask about an audit or other services, and to set up documentation that holds up under review.

For a closer look at this, see our overview of website compliance accessibility consultant.