With the official implementation of the EU Accessibility Act (EAA) on June 28, 2025, ICT product and service providers are required to provide accessibility conformity assessment reports that comply with the EN 301 549 standard. The following is a detailed guide about the evaluation report:
Core elements of evaluation report
1. Basic structure of the report
Product Overview: including basic information such as product name, version number, and scope of application
Applicable standard: Clearly adopt EN 301 549 version (currently recommended V3.2.1)
Evaluation method: Detailed description of the testing methods and tools used
Declaration of conformity: an explanation of the degree of conformity to each requirement
2. Key evaluation contents
The evaluation needs to cover the following technical indicators:
Non textual content: All images, charts, and videos must provide textual alternative explanations
Operational adaptability: supports various interactive methods such as keyboard operation and voice control
Visual adaptability: Text size can be adjusted up to 200% without losing functionality
Assistive technology compatibility: compatible with mainstream screen readers, enlargement software, etc
Mainstream evaluation tools and methods
VPAT Template Application
The Voluntary Product Accessibility Template (VPAT) is currently the most widely used evaluation report format, which includes:
Standardized evaluation framework
Detailed requirement list (corresponding to clause EN 301 549)
Test result record
Defect description and improvement plan
Large enterprises such as Microsoft have publicly released a VPAT based Assistive Function Consistency Report (ACR) as a reference.
Evaluation Method System
Functional testing: Verify the barrier free implementation of basic functions
Compatibility testing: cross device, cross platform testing
User experience testing: Invite people with disabilities to participate in actual usage testing
Automated scanning: preliminary screening using accessible detection tools
EU market compliance requirements
Applicable product scope
Consumer electronics products such as smartphones and computers
Self service terminals such as bank ATMs and ticket machines
Enterprise software and cloud service platform
E-books and digital documents
Time node requirements
New products entering the EU market after June 28, 2025 must provide compliance certification
Existing products should undergo evaluation and necessary improvements by 2025
Suggestions for Chinese enterprises to respond
Early assessment: Include accessibility considerations in the product design phase
Third party verification: Consider hiring a professional accessibility agency for evaluation
Continuous improvement: Establish an accessible problem response and repair mechanism
Document preparation: Bilingual reports in Chinese and English are more conducive to international market acceptance
Common problem solutions
For the issues identified in the evaluation, typical improvement measures include:
Add subtitles and audio descriptions to multimedia content
Optimize the minimum click area of UI controls (not less than 44 × 44 pixels)
Provide sufficient color contrast (at least 4.5:1)
Ensure that all functions can be completed through keyboard operation
As countries such as Australia also adopt similar standards (such as AS EN 301 549:2024), products that meet the requirements of EN 301 549 will have broader market access.
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