EAA Readiness Checklist

Evidence to keep: A written scope determination naming the category, the Member States served, and the consumer-facing channels (website, app, e-tickets, terminals) it covers.

Note: The six categories are electronic communications services, services providing access to audiovisual media services, listed elements of air, bus, rail and waterborne passenger transport, consumer banking services, e-books and dedicated software, and e-commerce services. Article 3(30) defines e-commerce services as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract, so any online consumer sales journey is in scope. Business-only services fall outside Article 2(2) because Article 3(22) limits 'consumer' to natural persons acting outside their trade, business, craft or profession.

Evidence to keep: Product register mapped to the Article 2(1) list with the date each product was placed on the market.

Note: Covered products: consumer general purpose computer hardware systems and their operating systems; payment terminals; automated teller machines, ticketing machines, check-in machines and interactive information terminals dedicated to covered services; consumer terminal equipment used for electronic communications services; consumer terminal equipment used for accessing audiovisual media services; and e-readers. Terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock are excluded.

Evidence to keep: Dated headcount and annual turnover or balance sheet total, re-checked each financial year, with a note of the national transposition provision relied on.

Note: Article 3(23): fewer than 10 persons employed and an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Article 4(5) exempts microenterprises providing services from the Article 4(3) service requirements and any obligations relating to them. It does not exempt microenterprises dealing with products from the product requirements; Article 14(4) and Article 14(8) only relieve them of documenting and notifying an Article 14 assessment. Crossing either threshold ends the exemption. Article 4(6) obliges Member States to publish guidance and tools for microenterprises, which are worth checking in each country.

Evidence to keep: Content inventory listing each excluded item, the exclusion ground, and its publication or last-edit date.

Note: Excluded: pre-recorded time-based media published before 28 June 2025; office file formats published before 28 June 2025; online maps and mapping services where essential information for navigational maps is provided in an accessible digital manner; third-party content that is neither funded, developed by, nor under the control of the economic operator; and archives whose content is not updated or edited after 28 June 2025. Editing an archived page or re-publishing an old PDF removes the exclusion. Embedded payment or identity widgets that you pay for or configure are under your control and are not third-party content for this purpose.

Evidence to keep: Register of Member States served, with the national instrument, its penalty provisions and the designated authorities for each.

Note: The Directive binds Member States; the duties you answer to are in national law, applied from 28 June 2025 (Article 31(2)). Member States could delay only the Article 4(8) emergency-communications duty, to 28 June 2027 at the latest (Article 31(3)). EUR-Lex lists the measures each Member State has communicated under the national transposition tab for CELEX 32019L0882.

Evidence to keep: Accessibility audit reports for each site and app in the consumer journey against WCAG 2.2 Level AA or EN 301 549 clauses 9 and 11, with retest records and an open issues log.

Note: Perceivable, operable, understandable and robust are the four WCAG principles. The practical benchmark is EN 301 549, whose web and software clauses incorporate WCAG at Level AA: v3.2.1 uses WCAG 2.1 and v4.1.1, published by ETSI on 2 September 2026, uses WCAG 2.2. As of 19 October 2026 no edition of EN 301 549 is cited in the Official Journal under this Directive, so conformance is strong evidence rather than a legal presumption until that citation lands (see the harmonised standards section).

Evidence to keep: Register of products used in the service, with each product's EU declaration of conformity or accessibility documentation from the manufacturer.

Note: Article 32 allows products lawfully in use before 28 June 2025 to stay in service until 28 June 2030, and self-service terminals for up to 20 years from entry into use where national law provides for it. Products brought into use after 28 June 2025 must comply now.

Evidence to keep: The published service and accessibility information, its URL or location, and its last review date.

Note: This is the same information the Annex V document under Article 13(2) describes; one accessible document can serve both, provided it meets the format requirements in the next six rows.

Evidence to keep: Information published as accessible text that works with screen readers and can be read aloud; any audio or video version carries captions and a transcript.

Note: Text that a screen reader can read already reaches sight and hearing. Image-only PDFs and video without transcripts do not.

Evidence to keep: Plain-language review of the published information; reading-level check; glossary for unavoidable technical terms.

Note: The Directive sets no reading level for general services. It does for consumer banking (CEFR level B2, Annex I, Section IV, point (e)(ii)), which is a sensible target everywhere.

Evidence to keep: Contrast, zoom and reflow checks on the pages or documents carrying the information.

Note: Maps to the WCAG Perceivable principle: text alternatives, adaptable structure and distinguishable presentation.

Evidence to keep: Information published as HTML or tagged, text-based documents rather than images or scanned PDFs; braille or large-print versions can be generated on request.

Note: Real text is what lets users switch to braille, large print, speech or high contrast.

Evidence to keep: Contrast ratio results, text resize to 200% and text spacing override tests (WCAG 1.4.3, 1.4.4 and 1.4.12) on the information pages.

Note: Fixed-height containers that clip text when spacing is increased are the usual failure.

Evidence to keep: Alt text audit of diagrams, icons and screenshots; transcripts and audio description for video explainers.

Note: Covers the instructional diagrams, icons and videos in help centres and onboarding flows, not just marketing images.

Evidence to keep: Accessibility checks on transactional emails, invoices, statements, confirmations, e-tickets and downloadable PDFs (tagged PDF or PDF/UA results).

Note: This point reaches beyond the website to every electronic document the service sends or generates. Untagged PDF invoices and image-based e-tickets are common gaps.

Evidence to keep: Support scripts or knowledge-base entries on accessibility features and assistive technology compatibility; staff training records; at least one text-based and one voice-based contact channel; relay or video service details where offered.

Note: A phone-only helpline fails a deaf customer; a chat-only helpline can fail a blind customer if the chat widget is inaccessible. Offer both and test both.

Evidence to keep: Product data model and listing templates with a field for manufacturer-supplied accessibility information; a process for collecting it from suppliers or marketplace sellers.

Note: The duty is to pass through accessibility information supplied by the manufacturer or service provider, not to author it. Marketplaces should capture it at seller onboarding.

Evidence to keep: Audit results for account creation, login, multi-factor authentication, CAPTCHA alternatives, basket, checkout, address entry, card entry and 3-D Secure steps, including third-party iframes.

Note: WCAG 2.2 added 3.3.7 Redundant Entry and 3.3.8 Accessible Authentication (Minimum), which target exactly these steps. Payment gateway iframes you embed are part of your service.

Evidence to keep: Test results for each identity provider, e-signature flow and payment method offered (wallets, buy-now-pay-later, bank redirects); accessibility clauses in supplier contracts.

Note: Where a bank redirect or wallet provider is inaccessible, offer an accessible alternative payment route and document the remediation request you made to the supplier.

Evidence to keep: Product list mapped to the five Article 3(28) heads, with the underlying Union act for each.

Note: The five heads are consumer and mortgage credit agreements (Directives 2008/48/EC and 2014/17/EU), the listed investment services and activities (points 1, 2, 4 and 5 of Sections A and B of Annex I to Directive 2014/65/EU), payment services (Directive (EU) 2015/2366), services linked to a payment account (Directive 2014/92/EU) and electronic money (Directive 2009/110/EC).

Evidence to keep: Audit results for onboarding and identity verification, strong customer authentication, card and app PIN entry, e-signature of agreements, transfers and card controls; an accessible alternative to any biometric-only or image-based step.

Note: Annex I, Section I, point 2(l) requires products to offer an alternative to biometric identification and control; apply the same principle to app-based authentication.

Evidence to keep: Plain-language review records for terms and conditions, fee information, product pages, app copy and letters; readability test results; an editorial standard that names B2.

Note: This is the only reading-level requirement in the Directive. It applies to the information the service provides, which includes contractual and pre-contractual documents, not just marketing pages.

Evidence to keep: Media overlays or an equivalent synchronisation mechanism present in read-aloud titles; QA checks on a sample of titles.

Note: EPUB 3 media overlays are the usual mechanism.

Evidence to keep: Screen reader and refreshable braille test results on representative titles across the reading apps you offer; automated EPUB accessibility checks.

Note: Dedicated reading apps are part of the service under Article 3(41) and also fall under the general website and app requirement in Annex I, Section III, point (c).

Evidence to keep: Titles ship with a navigable table of contents, a page list where relevant, headings and a logical reading order; reflowable layout or an accessible alternative to fixed layout; user control of font, size, spacing and colours in the reading software.

Note: Fixed-layout files with no reflow and no structure fail this point even if the text is real.

Evidence to keep: Text-to-speech, braille output and visual adjustment verified across the platforms supported; image descriptions present; MathML or described alternatives for formulae.

Note: Alternative renditions means the same content delivered as speech, braille, large print or high contrast, not a separate accessible edition.

Evidence to keep: Accessibility metadata present in each file and in the catalogue feed, and surfaced on product pages.

Note: EPUB accessibility metadata (the schema.org accessibility properties in the package document) and the ONIX accessibility codes are the industry mechanisms; retailers should display them to customers.

Evidence to keep: DRM configuration review confirming that text-to-speech, screen reader access, font and colour changes and braille output are not disabled; test results on protected files.

Note: DRM settings that switch off read-aloud or restrict the choice of reading system are the most common failure.

Evidence to keep: Inventory of websites, mobile services and apps, electronic tickets and ticketing services, channels delivering transport information including real-time information and interactive information screens in the Union, and interactive self-service terminals in the Union.

Note: For urban, suburban and regional transport services (rail, bus and coach, metro, tram and trolley bus under Article 3(35) and (36)) only point (v), interactive self-service terminals, applies. Terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock are excluded.

Evidence to keep: Published, accessible pages covering step-free access, on-board facilities, station or terminal accessibility and how to book assistance, kept current.

Note: Article 5 deems services that meet the accessible-information duties in the passenger rights Regulations to meet the corresponding EAA requirement, but any additional EAA requirement applies in full.

Evidence to keep: Accessibility checks on the booking flow, journey planner, live departure boards and disruption alerts across web, app and interactive screens; a process for publishing lift and staffing status in accessible form.

Note: Interactive information screens are covered only where located within the territory of the Union (Article 2(2)(c)(iv)).

Evidence to keep: Terminal register with the Section I conformity evidence from each supplier and the Article 32(2) entry-into-use date for legacy terminals.

Note: These services are exempt from the general Section III requirements under Article 4(3); the terminal duty and the product rules are what apply.

Evidence to keep: Cross-reference table between Regulations (EC) No 261/2004, (EC) No 1107/2006, (EC) No 1371/2007, (EU) No 1177/2010 and (EU) No 181/2011 and the Annex I requirements.

Note: The rail Regulation the Directive cites, (EC) No 1371/2007, has since been recast as Regulation (EU) 2021/782.

Evidence to keep: Real time text available on the voice service across supported networks and devices; interoperability test records.

Note: Article 3(14) defines real time text as text sent so that the conversation is perceived as continuous, character by character, not message by message.

Evidence to keep: Synchronised voice, real time text and video supported on the video calling service; test records.

Note: Total conversation service is defined by reference to Directive (EU) 2018/1972 (Article 3(9)).

Evidence to keep: Emergency call routing and media synchronisation test records agreed with the national public safety answering point operator.

Note: The answering side of 112 is a Member State duty under Article 4(8) and Annex I, Section V.

Evidence to keep: Accessibility audit of the programme guide on each platform; accessibility indicators (subtitles, audio description, sign language) shown per programme.

Note: Article 3(6) expressly includes electronic programme guides within the service.

Evidence to keep: End-to-end checks that access services supplied by broadcasters survive encoding and delivery; player settings that let users switch each access service on and off and adjust its presentation.

Note: Dropping or desynchronising subtitles in the delivery chain fails this point even where the broadcaster supplied them correctly.

Evidence to keep: National public safety answering point capability documentation and test records.

Note: Article 31(3) allowed Member States to apply this duty at the latest from 28 June 2027. Listed so the full Annex I picture is visible; private operators can mark it not applicable.

Evidence to keep: Requirements traceability from Annex I to design specifications; test reports against the EN 301 549 hardware and software clauses.

Note: Article 11 makes an importer or distributor a manufacturer when it places a product on the market under its own name or trademark, or modifies a product in a way that may affect compliance.

Evidence to keep: Label and on-device text review; tactile or audio alternatives for key markings.

Note: Section I opens with the general duty to design and produce products so as to maximise their foreseeable use by persons with disabilities, accompanied where possible by accessible information on their functioning and accessibility features.

Evidence to keep: Accessible online manual containing the required descriptions and the list of assistive technologies tested; publication no later than placing on the market.

Note: Points (vii) and (viii) require a point-by-point statement of which of the Section I, point 2 features the product provides.

Evidence to keep: Feature-by-feature conformance matrix against points 2(a) to 2(n); usability test results with assistive technology users.

Note: Point 2(c) also requires interoperability with programmes and assistive devices used to navigate the interface.

Evidence to keep: Test reports for each applicable sector point; hearing technology compatibility results.

Note: Self-service terminals include payment terminals, ATMs, ticketing machines, check-in machines and interactive information terminals (Article 2(1)(b)).

Evidence to keep: Support scripts, training records and accessible contact channels.

Note: The service-side twin of this duty is Annex I, Section III, point (d).

Evidence to keep: Packaging review; accessible online instructions meeting the six format requirements in point (b).

Note: Section II applies in addition to Section I. When feasible, accessible information about the product's accessibility characteristics should be provided on the package itself.

Evidence to keep: Technical documentation with a general description of the product and the list of harmonised standards or technical specifications applied, or the solutions adopted where none were applied; a signed EU declaration of conformity per product model; CE marking on each product.

Note: Annex IV, point 2 also requires the technical documentation to demonstrate any Article 14 fundamental alteration or disproportionate burden relied on. There is no notified body route: the manufacturer declares conformity on its sole responsibility, and under Annex IV, point 5 an authorised representative may handle the CE marking and declaration if the mandate says so.

Evidence to keep: Change control procedure with an accessibility impact step; standards watch covering EN 301 549.

Note: Article 7(4) is the product-side equivalent of Article 13(3) for services.

Evidence to keep: Label artwork, packaging and accompanying documents for each market.

Note: Importers carry parallel duties under Article 9(4) and (5), and distributors verify both sets under Article 10(2).

Evidence to keep: Corrective action procedure, authority notification template, and the register of non-compliant products and complaints.

Note: Importers (Article 9(8)) and distributors (Article 10(5)) have equivalent duties.

Evidence to keep: Evidence pack ready to release: technical documentation, EU declaration of conformity, test reports and any Article 14 assessment.

Note: Article 12 adds that economic operators must be able to identify who supplied them with a product and whom they supplied it to, for five years in each direction.

Evidence to keep: Pre-market verification checklist per product; copy of each EU declaration of conformity; importer contact details on the product or packaging.

Note: Article 9(6) also requires storage and transport conditions that do not jeopardise compliance.

Evidence to keep: Goods-in verification records; escalation procedure for suspected non-compliance.

Note: Article 10(4) also requires storage and transport conditions that do not jeopardise compliance.

Evidence to keep: Accessibility requirements built into design, procurement and development processes; audit results showing the requirements are met.

Note: This is the umbrella duty; the Annex I rows above are its content.

Evidence to keep: The published accessibility information, included in the general terms and conditions or an equivalent document, describing the applicable requirements and covering the design and operation of the service.

Note: Annex V calls for inclusion in the general terms and conditions or an equivalent document; an accessibility statement that the terms link to is the common approach. This is distinct from the EU declaration of conformity, which exists only for products (Article 16).

Evidence to keep: Section of the published information describing what the service is and the channels it is delivered through.

Note: Annex V, point 1 adds that this information sits on top of the consumer information duties in Directive 2011/83/EU.

Evidence to keep: Section explaining how customers use the service, including its accessibility features and assistive technology compatibility.

Note: Overlaps with Annex I, Section III, point (b); write it once and reference it from both places.

Evidence to keep: Requirement-by-requirement account covering Section III points (a) to (d) and the sector points that apply, citing the audit evidence and any harmonised standard or technical specification applied in full or in part.

Note: Annex V, point 2 lets you apply harmonised standards or technical specifications cited in the Official Journal to meet this point. Until an edition of EN 301 549 is cited under the EAA, describe your WCAG and EN 301 549 results as evidence, not as a presumption of conformity.

Evidence to keep: Accessible web page or document; a telephone or in-person channel whose staff can give the same information orally; alternative formats on request.

Note: Oral format is explicit in the Directive; a published page alone does not satisfy it.

Evidence to keep: Version history or archive of the published information with dates.

Note: Keep superseded versions too, so you can show what was published at any point.

Evidence to keep: Description of accessibility quality gates, release testing, periodic audits and complaint monitoring, with the cadence and the owner.

Note: Authorities read this as the service provider's accessibility management system.

Evidence to keep: Change management checkpoint for accessibility; standards watch that tracks the Official Journal citation of EN 301 549 v4.1.1 and any technical specifications adopted under Article 15(3).

Note: Article 13(3) applies without prejudice to the Article 32 transitional measures.

Evidence to keep: Corrective action procedure naming the authority for each Member State; notification template; log of notifications made.

Note: The duty to inform is immediate and applies in every Member State where the service is provided, not only where the problem was found.

Evidence to keep: Evidence pack ready to release: audit reports, the Annex V information, monitoring records and any Article 14 assessment.

Note: Article 23(1)(a) ties the authorities' checks to the Article 14 assessment as well, so keep both together.

Evidence to keep: A dated decision note; where reliance is intended, the list of specific requirements and the services or products it concerns.

Note: Fundamental alteration means a significant change that alters the basic nature of the product or service. Disproportionate burden is judged against the Annex VI criteria. The requirements still apply to the extent compliance does not cause either, so reliance is requirement by requirement, not a blanket exemption.

Evidence to keep: The completed assessment, covering each Annex VI criterion in the rows below.

Note: Article 14(7) empowers the Commission to adopt delegated acts further specifying the criteria; check whether any such act applies.

Evidence to keep: Cost model listing the one-off organisational costs (additional accessibility staff, training, a new accessibility process, guidance material, understanding the legislation) and ongoing costs (design of accessibility features, manufacturing, testing, documentation) under Annex VI, point 1(a)(i) to (v) and point 1(b)(i) to (iv).

Note: Net cost means the cost of compliance over and above what you would spend anyway; a redesign you were doing regardless is not a compliance cost.

Evidence to keep: Benefit estimate with usage data for the product or service and the population of users affected.

Note: Article 14(7) directs the Commission, when refining the criteria, to count benefits for persons with functional limitations as well as persons with disabilities.

Evidence to keep: Net turnover figure and the same net cost elements as Annex VI, point 1, broken down under point 3(a) and (b).

Note: Points 1 and 3 use the same cost elements with different denominators; prepare the cost breakdown once.

Evidence to keep: Signed assessment with the retention date; a copy ready for the service compliance authority or market surveillance authority.

Note: Article 14(4) exempts microenterprises dealing with products from documenting the assessment, but they must still supply the relevant facts if a market surveillance authority asks.

Evidence to keep: Renewal schedule with the next due date and triggers tied to the change management process.

Note: A service first assessed in June 2025 needs a fresh assessment by June 2030 at the latest, earlier if the service changes.

Evidence to keep: Statement from finance on accessibility-specific grants, subsidies or funding, reviewed annually.

Note: The bar applies only to disproportionate burden (Article 14(1)(b)), not to fundamental alteration.

Evidence to keep: Copies of the notifications sent, with dates and recipients.

Note: Microenterprises are exempt from this notification under the second subparagraph of Article 14(8).

Evidence to keep: Asset register with entry-into-use dates and a replacement plan that completes before 28 June 2030.

Note: The transition covers the products used in the service, not the service itself. Websites, apps and new content had to comply from 28 June 2025.

Evidence to keep: Contract register with signature and expiry dates; a flag on any amendment, since alteration ends the protection; a plan for contracts that would otherwise run past 28 June 2030.

Note: Five years from 28 June 2025 is 28 June 2030. A renewed or amended contract is a new contract for this purpose.

Evidence to keep: Terminal register with entry-into-use dates, the national provision relied on, and the resulting end date for each terminal.

Note: This is a Member State option (the Directive says Member States may provide), so check the national transposition before relying on it.

Evidence to keep: A short note in the compliance file confirming the transitional period is applied only to pre-existing products, contracts and terminals.

Note: This is the most common misreading of Article 32.

Evidence to keep: Register of authorities per Member State with contact routes.

Note: Article 23(2) obliges Member States to inform the public of the existence, responsibilities, identity, work and decisions of these authorities. Several Member States split responsibility by sector (a telecoms regulator for electronic communications, a financial regulator for banking, a consumer authority for e-commerce), so the register may hold more than one authority per country.

Evidence to keep: Published accessibility contact in the Annex V information; complaint log with response times; link to the corrective action procedure.

Note: The Directive does not prescribe a feedback form, but Article 23(1)(b) obliges authorities to follow up complaints about services, Article 29(2)(a) gives consumers the right to act before courts or administrative bodies, and Article 29(2)(b) lets public bodies and associations with a legitimate interest act on a complainant's behalf or in support. A complaint you did not answer is the usual trigger for an authority's first letter.

Evidence to keep: Penalty summary per Member State in the compliance file, with the maximum fines or other sanctions and the remedial powers of the authority.

Note: Article 30 requires penalties that are effective, proportionate and dissuasive, accompanied by effective remedial action, and that take into account the extent and seriousness of the non-compliance, the number of units of non-complying products or services and the number of persons affected. Article 29(3) and Article 30(5) exclude procurement procedures under Directives 2014/24/EU and 2014/25/EU.

Evidence to keep: Standards watch entry naming the edition of EN 301 549 relied on, its Official Journal citation status under this Directive, and the date last checked.

Note: As of 19 October 2026 no edition of EN 301 549 is cited in the Official Journal under this Directive. EN 301 549 v3.2.1 is cited under the Web Accessibility Directive (Directive (EU) 2016/2102) only and gives no presumption of conformity under the EAA. ETSI published v4.1.1, aligned to WCAG 2.2 and mapped to the EAA requirements, on 2 September 2026; its citation under the EAA is expected in late November or December 2026. Until then conformance with EN 301 549 is strong evidence of meeting Annex I, not a legal presumption.

Evidence to keep: Note in the standards watch of any implementing act establishing technical specifications, or confirmation that none applies.

Note: Technical specifications can be adopted only where no harmonised standard reference is published and either the standardisation request has stalled or been refused, or the Commission can show the specification meets the Annex II criteria of Regulation (EU) No 1025/2012.