EAA -- Feedback Mechanisms

What It Is

Two EU directives sit on top of each other when a user needs to report an accessibility barrier, and they impose different obligations on different entities. Getting them confused is the fastest way to publish a non-conformant accessibility statement.

The Web Accessibility Directive (WAD, Directive (EU) 2016/2102) Article 7(1)(b) requires every public-sector body to publish an accessibility statement that includes "a description of, and a link to, a feedback mechanism" enabling any person to notify the body of failures to comply and to request information that has been excluded from the scope of the directive^[1]. Article 9 then requires Member States to stand up an enforcement procedure the user can escalate to if the body's response is unsatisfactory or absent^[1].

The European Accessibility Act (EAA, Directive (EU) 2019/882) does not require private-sector service providers to host a user-facing feedback channel the way WAD does. Enforcement runs through Article 25, which directs Member States to check the compliance of services with the directive's obligations and to follow up on complaints or reports related to non-compliance, and Article 29, which directs Member States to ensure that adequate and effective means exist for consumers to take action for compliance with the directive^[2]. The practical consumer route under the EAA is a complaint to the national market-surveillance or service-compliance authority, not a form on the service provider's own site.

Why It Matters

A blind user hitting a broken checkout flow, a deaf user who cannot locate captions, a screen-reader user whose ticket-booking screen exposes an unlabeled SVG -- all of these are barriers the regulator expects to be reportable. On a public-sector site, WAD Article 7 makes the feedback channel a conformance artifact: if the accessibility statement does not link to one, the statement itself fails the directive before anyone evaluates a single WCAG criterion. On an EAA-scope service, the absence of a provider-side channel is not itself a WAD violation, but it removes the only cheap route to fix a barrier before a consumer files with the national enforcement body.

How It Relates to WCAG

Feedback mechanisms are not a WCAG success criterion. WCAG 2.2 evaluates the page that was delivered; the feedback obligation governs the procedural wrapper around the page. Every Success Criterion in WCAG 2.2 Level AA could pass on every page and the site would still fail WAD Article 7 if the feedback link is missing, and a site with a working feedback mechanism can still fail countless WCAG criteria on every page. The two layers are independent and both are required.

Practical Implications

• Public-sector bodies (WAD Article 7 scope). Publish an accessibility statement that includes a feedback mechanism link reachable from every page -- a dedicated form, a monitored email address, or a contact page that accepts accessibility reports. Route submissions to a named owner, not a generic support queue. Respond within the timeframe the national transposition sets (commonly 30 days); the directive itself only says "in an adequate manner"^[1].
• Public-sector bodies, escalation link. Article 7(1)(b) also requires the statement to link to the enforcement procedure established under Article 9. This is the ombudsman or equivalent body the user can escalate to when the initial response is missing or inadequate^[1]. Omitting the escalation link is itself a WAD non-conformance, regardless of how responsive the feedback channel is.
• EAA-scope service providers. The EAA does not mandate a provider-hosted feedback form. It does require service providers to ensure their services meet the applicable accessibility requirements in the directive's annexes and to document how the service meets them^[2]. That published conformance information is not a substitute for a feedback channel, and a feedback channel is not a substitute for the documentation.
• EAA-scope consumer complaint path. Article 29 requires Member States to ensure adequate and effective means exist for consumers to take action for compliance with the directive's obligations, and Article 25 routes service non-compliance complaints through the national compliance-checking body^[2]. Any user-facing page about accessibility feedback on an EAA-scope service should name that national authority and link to its complaint form.
• Channel accessibility. The feedback mechanism itself must be accessible. A phone-only complaints line fails deaf users; a form that traps focus in a <div>-based modal fails keyboard users; an email address rendered as an image fails screen-reader users. Test the feedback path against the same WCAG 2.2 AA bar as the rest of the site.
• Tracking. Log accessibility-specific submissions separately from general support so the pattern of reports is visible to the team that can fix them. A report that does not reach the product owner is equivalent to no report.

Related Clauses

• EAA accessibility statements
• 12.2 Support services