When you read through the European Accessibility Act (EAA) documentation requirements, there’s a lot of documents that economic operators are required to have, but there’s no specific mention of a VPAT/ACR. However, if you read through the language, an ACR for your product or service makes a lot of sense.
(Note: An ACR is just a filled in and completed VPAT.)
Let’s look at what the EAA actually mandates. According to Annex IV, manufacturers must establish technical documentation that:
“shall make it possible to assess the conformity of the product to the relevant accessibility requirements referred to in Article 4”
The Directive (EAA Annex IV, Section 2) gets more specific about what this documentation should contain, requiring:
“descriptions of the solutions adopted to meet the relevant accessibility requirements referred to in Article 4 where those harmonised standards or technical specifications have not been applied”
That’s helpful, but do you notice what’s missing? Any mention of the specific type of documentation.
The Authority Request
Here’s where ACR documentation becomes very compelling. Article 7(9) creates a requirement that fundamentally changes how you should think about documentation:
“Manufacturers shall, further to a reasoned request from a competent national authority, provide it with all the information and documentation necessary to demonstrate the conformity of the product, in a language which can be easily understood by that authority.”
Think about that phrase: “in a language which can be easily understood by that authority.” This isn’t just about translation – it’s about presenting information in a format that regulatory officials can quickly parse and evaluate. When market surveillance authorities make a request, you’ll want to have documentation that is clear and to the point.
Why ACRs Work
VPATs haven’t been bestowed any type of formal EU approval, but they’re used across the global marketplace for accessibility reporting and they’re structured so that they could easily demonstrate compliance with the technical requirements found in Annex 1.
When you provide an ACR to an EU market surveillance authority, I can’t think of any better documentation you could have (so long as you approach the VPAT process the right way and the ACR is issued by a reputable service provider like Accessible.org, my company). Let’s continue on.
The five-year documentation requirement from EAA Article (3) adds another layer here:
“Manufacturers shall keep the technical documentation and the EU declaration of conformity for five years after the product has been placed on the market.”
That’s a long time to maintain useful, understandable documentation. Try explaining your accessibility decisions from 2020 using informal notes versus a properly completed VPAT – the structure matters.
Efficiency
VPATs/ACRs are increasingly being requested in the United States and internationally anyway. With Section 508 and ADA compliance becoming a priority, we’re seeing procurement agents require that vendors have an ACR as part of the procurement agencies.
So even if not specifically for EAA compliance, you’ll likely need an ACR anyway.
Not Required
Again, there’s nothing in the EAA that requires a VPAT/ACR, but given all of the above, having an accounting of your accessibility makes a lot of sense and VPATs have been internationally recognized documentation for accessibility for years — including in the European Union.
Accessible.org Services
Do you need help with EAA compliance? We provide accessibility audits and VPAT services specifically that directly support European Accessibility Act’s requirements.
We’d love to help. Just visit Accessible.org for a quote.