A Web Accessibility Evidence Pack For The European Accessibility Act
Ran Ronen, Founder and CEO of Equally AI, part of AudioEye, helping companies achieve compliance with ADA, EAA, and WCAG requirements.
Many companies treated the European Accessibility Act as a deadline problem. Build an accessibility page; add a clause to your terms; check the box. The deadline passed. The problem didn’t.
What many leaders don’t realize is that the EAA is not a compliance exercise. It’s an evidence standard. Regulators are focused not just on effort, but on documented proof. As PwC notes, “Companies are obligated to document their compliance initiatives and be prepared to provide evidence to national authorities proving that they meet the Act’s requirements.”
The law operates on two layers: what companies say publicly and what they can show privately. Public evidence is what anyone finds on the website. Internal evidence is what companies keep on file and provide when asked. The directive requires both layers. Think of it simply: Public is what the company says. Internal is what proves it.
You’ll want to discuss your specific situation with legal counsel, but here’s a general framework to help companies prepare.
Part 1: What Companies Publish
This is the public layer, what regulators and customers actually see. Two things go live on a company’s website: one page and one clause. I’ve noticed many companies publish a generic accessibility page that looks formal but proves nothing, and that can be a mistake.
Accessibility Statement Page
This is a single required page, usually located at /accessibility. It is not just a statement, but a structured explanation of the service and how it handles accessibility.
1. A clear, findable page confirms the company’s commitment, lists the legal entity and provides a real contact method, and people must be able to find the page.
2. Scope and covered journeys explain what is included and what is not, listing key flows like login, checkout and support so it is clear how people interact with the service.
3. Measures, standards and monitoring explain how the business handles accessibility, which standards it follows, like WCAG 2.2 AA or EN 301 549, how often it is reviewed and who is responsible.
4. Accessible formats and barrier reporting give people a way to report problems through email, phone or callback.
New Clause In The Terms And Conditions
This clause is separate from the page because it sits inside a legal document and connects the legal agreement to the company’s accessibility commitments. Example: “Accessibility information for this service is available at [URL]. That page describes the scope of our accessibility work, the standards we use, how information can be requested in another format and how barriers can be reported.”
Keeping a record of every version of this clause can help prove what was published at any given time.
Part 2: What Companies Keep Internally
This is where many companies stop. They publish the page, add the clause and think they are done. The problem is that what companies publish is only the claim. What comes next is the supporting layer, what the company shows when someone asks for evidence. Internal evidence is not public; it is stored and shared only when needed. For many companies, this layer also supports enterprise procurement.
Internal Control And Response System
This shows the company is not reacting randomly. They have a defined way to manage accessibility.
Includes:
• A legal response plan defines how to act when a legal or regulatory issue arises.
• A complaint handling process shows how accessibility issues are received and managed.
• Clear ownership and response times define who is responsible and how quickly issues are handled.
In simple terms, this answers: “What happens when something goes wrong?”
Monitoring And Reporting Evidence
This shows the scope of what the company actually checks, how it is checked and how often it is reviewed.
Includes:
• Which digital products are in scope, such as websites, subdomains, mobile apps, portals, authenticated areas and key documents.
• How monitoring is performed, whether through automated accessibility scanning, manual review, expert testing or a combination of methods.
• Issue summaries highlight key problems and their impact on accessibility.
• How often monitoring takes place, such as daily, weekly, monthly or after major releases.
• What the reporting shows, including issue summaries, changes over time and areas that need action.
Monitoring means regularly checking the digital products in scope for accessibility issues and keeping a record of what was reviewed, what was found and what happened next. Reports show that this is an ongoing process, not a one-time effort.
Issue Tracking And Remediation
In my experience, this is the most important part. Every issue must be tracked from discovery to fix.
Includes:
• What the issue is
• Where it exists
• Who owns it
• When it will be fixed
• When it was fixed
Remediation simply means fixing the issue. This shows action, not intention.
Accessibility Certification Documents
A VPAT is a structured accessibility report that shows how the product performs against standards like WCAG or EN 301 549. It is what large companies and public sector buyers review before approval and answers one question: Can this product be used by people with disabilities, and where are the limitations?
Ready-To-Send Proof
One practical approach is to consolidate this into a single evidence pack so companies can respond quickly if asked, including:
• Accessibility page snapshot
• Terms clause
• Internal processes
• Reports
• Audit summaries
• Issue tracking
• Complaint logs
• Version history
Since officials must “ensure that a decision on each complaint is taken within a reasonable time limit,” I’ve found companies that respond quickly with clear documentation tend to be in a stronger position than those that take weeks with incomplete records.
Final Takeaway
Successful companies can show what exists, what was fixed and what is next. If a company can clearly publish, track and prove their work, I’ve found they are already ahead of most of the market.
The information provided here is not legal advice and does not purport to be a substitute for advice of counsel on any specific matter. For legal advice, you should consult with an attorney concerning your specific situation.
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