Do I need to prove that I have tested my site?

A declaration shows your own testing, not a separate test report

Yes, the directive expects a service provider to demonstrate how the service meets the accessibility requirements, and this is not done with a separate scan report but with the accessibility declaration that the directive prescribes. It describes how the service — the webshop, the checkout process, the login flow — meets the requirements of the directive, and where it does not yet. This is an explanation in plain language, not a technical test log, and the directive leaves the format free; the content is fixed.

An automated scan can help here, but does not prove a declaration by itself. A scan finds most of the errors that can be recognized automatically — poor contrast, missing labels, missing headings — but whether alternative text truly describes an image or whether the checkout process remains logical with keyboard only is not assessed by any scan. Anyone who can demonstrate having tested supports this with what was checked and how, without a scan report itself serving as proof of conformity. For those who fall under the exemption for micro-enterprises — fewer than ten employees and a turnover of no more than two million euros, both — this obligation does not apply anyway; the scope check will tell you this.

Where this follows from the directive

This follows from directive (EU) 2019/882 (the EAA): the general accessibility requirements for services are set out in Article 4, and the obligation for service providers to document how their service meets those requirements is set out in Article 13 with Annex V. What is organized around this declaration in each country — the language, and which market surveillance authority reviews it — does vary: in the Netherlands the format is free and the ACM oversees it, in Germany the Erklärung zur Barrierefreiheit must be in German and is overseen by the Marktüberwachungsstelle der Länder, in France the déclaration d'accessibilité is in French under the supervision of DGCCRF and ARCOM, and in Belgium the accessibility declaration must be in Dutch or French depending on the language region, under the supervision of the Economic Inspection.