EAA compliance has four requirements. Most organisations know about one of them.
Technical conformance
In practice this means WCAG 2.1 Level AA, the level EN 301 549 sets out. No harmonised standard has been cited in the Official Journal under the EAA, so EN 301 549 is what conformance is demonstrated against rather than something the Act requires. We track whether EN 301 549 has been cited under the Accessibility Act and date every check. This is the requirement most organisations are thinking about when they think about EAA compliance.
A published accessibility statement
A mandatory public declaration of your current compliance position, what is not yet accessible, and your remediation plan. Not optional. Most organisations we speak with don't have one. The absence of a statement is itself a compliance failure.
Active governance
A named owner for accessibility, a regular testing rhythm, and a process that survives a team change. Without governance, technical compliance regresses. A passing audit today doesn't mean a compliant product next quarter. The next sprint, the next team restructure, the next product release can all undo it.
Documentary evidence
Enforcement bodies don't just look for compliant products. They look for evidence of active management. Remediation records. Decision trails. Dated assessments. The documentation that shows the organisation was not simply ignoring the obligation.
The four requirements are related but they don't reinforce each other automatically. An organisation can have strong technical conformance and no governance to maintain it. It can have governance and no published statement. It can have all three and no documentary evidence trail. Each one is necessary. None is sufficient on its own.
Most organisations we speak with have made progress on the first. Very few have addressed all four. That gap is where enforcement exposure lives.
The assessment method used across Europe to measure compliance is the Solid Foundations Method. It checks whether the core elements users need to complete essential tasks are in place. Not every WCAG criterion, but the ones that matter most for logging in, making purchases, contacting support, making payments. It is an expert evaluation, but not a replacement for a full audit or user testing with disabled people. The two are related but not the same, and both matter.
The difference is process, not effort.
Find out where you stand across all four
Our free initial assessment covers whether EAA applies to your organisation, which of the four requirements you've addressed, and what a proportionate next step looks like.
Book your free assessment today