Regulatory Evidence Map

Status: ready

Intent

Connect the legal scope to user tasks, iOS profiles and evidence. Developers don't have to act as lawyers. Claims just stop floating above what the product actually does.

Problem

ADA, EAA, WAD, WCAG, EN 301 549, App Store labels and QA notes live in different documents. Nobody can say which task proves which claim.

Solution

Verdict: one small map per critical product area: market, rule, tasks, profiles, evidence, owner, release rule.

Why: the map is where product, QA, legal and engineering agree what has to be proved, and where a release reviewer checks that it was.

Regulatory brief

The law sets the scope.

ADA Title II (US):
  state and local government services
  technical standard: WCAG 2.1 Level AA for covered web content and mobile apps

ADA Title III (US):
  businesses open to the public
  legal review context, no technical standard in the regulation

Web Accessibility Directive (EU):
  public sector websites and mobile apps
  harmonised standard: EN 301 549 v3.2.1

European Accessibility Act (EU):
  covered products and services
  applies from 2025-06-28, with transition periods

Details: Legal context without legal theater.

Implementation

Area:       checkout
Markets:    US, EU
Rules:      ADA Title III risk, EAA (e-commerce service)
Tasks:      pay, recover a declined card, change payment method
Profiles:   VoiceOver, Larger Text AX5, Switch Control, Voice Control
Evidence:   transcripts, screenshots, CI audit, bug links
Owner:      payments product + QA
Review:     every release

A row with a stronger legal scope:

Rule:           European Accessibility Act
In scope:       ticketing service sold in the EU
Tasks:          search event, choose seat, pay, recover payment error
Mapping:        EN 301 549 / WCAG 2.1 where applicable
Evidence:       VoiceOver transcript, AX5 screenshots, Voice Control names
Release rule:   blocker if purchase or support can't be completed

Three rules for using the map:

Scope before checklist.
  Not "we need ADA compliance".
  "This is public sector parking payment. ADA Title II applies.
   The critical tasks are paying and contesting a ticket."

The law sets the minimum bar.
  Not "nice to have, fix later".
  "Covered public service. A VoiceOver user can't submit.
   Blocker, unless an accessible alternative exists."

Task before criterion.
  Not "4.1.2 is green".
  "A VoiceOver user can find Pay, hear the amount,
   recover from a declined card and pay again. 4.1.2 supports that."

Check

Profile:   release review
Task:      review the checkout map
Expected:  every critical task has evidence from this release
           every claim has an owner
           every vendor screen in a task has an acceptance record
           every failure has a decision

Pitfalls

  1. "Compliant" for the whole app from one screen.
  2. WCAG 2.2 as the legal reference where the rule points to 2.1.
  3. A WCAG table without an iOS walkthrough.
  4. Vendor evidence accepted without replaying the task.
  5. Failed evidence removed from release notes.

WCAG mapping

WCAG is the reference framework. EN 301 549 v3.2.1 is based on WCAG 2.1 with additional requirements. The ADA Title II rule uses WCAG 2.1 Level AA.

  1. Compliance Theater
  2. Vendor Blind Spot
  3. Scanner Theater
  4. App Store Label Drift
  1. Testing Evidence Record
  2. Evidence Based Release
  3. App Store Label Evidence
  1. Chapter 13
  2. Chapter 16
  3. Chapter 18
  1. Legal context without legal theater
  2. Accessibility testing toolkit

Sources

  1. ADA.gov: Title II web and mobile app rule
  2. European Commission: Web Accessibility Directive standards
  3. Your Europe: Accessibility requirements for services and products
  4. W3C WCAG 2.2