If consumers use your service directly online, you are the service provider under Art. 2.2(f) — the obligation is yours. If European banks embed your SDK/widget, they are obligated under Art. 2.2(d) — and they will require accessibility documentation from you contractually. In both cases, you need the same report.
Two business models, one accessibility requirement
B2C path: A consumer visits your website, uploads ID, signs a document, completes verification. Your website is an e-commerce service under Art. 2.2(f). You are directly obligated.
B2B path: A European bank integrates your signing widget in their account opening flow. The bank is obligated under Art. 2.2(d). The bank requires accessibility documentation from every third-party widget provider.
What the EAA requires from e-signature and identity verification interfaces
Document signing flow
Must be fully keyboard-operable. Typed signature or upload as alternatives to mouse-drawn. WCAG 2.1.1, 2.5.1.
Identity verification / KYC
Camera capture, document upload and liveness checks must have accessible alternatives. WCAG 1.1.1, 2.5.1.
OTP and authentication
OTP fields must be labelled. Countdown timers must announce time remaining. WCAG 1.3.1, 3.3.1.
Signed document output
The signed PDF must have a text layer. WCAG 1.1.1.
What you receive
Cover page
Compliance score, verification reference, date.
Identification and scope
Product, deployment context, evaluation method, legal framework.
17 WCAG 2.1 AA criteria
Criterion-by-criterion evaluation across four principles.
W3C remediation guidance
Actionable fixes per failed criterion.
Accessibility statement
Following Annex V of Directive 2019/882.
Legal basis and scope disclaimer
Directive 2019/882, EN 301 549 V3.2.1, national transposition.
What it costs
Three mistakes
"We're B2B, the EAA doesn't apply"
If you have ANY consumer-facing interface, Art. 2.2(f) applies directly. And even pure B2B, your European bank clients require the report.
Mouse-drawn or finger-drawn signature only
No typed-name or image-upload alternative fails WCAG 2.1.1 and 2.5.1.
Visual CAPTCHA or liveness check with no alternative path
Excludes users with visual or motor disabilities.
Enforcement
B2C = fines apply to you directly. B2B = fines apply to the bank; the bank drops your widget.
BFSG. Per-infringement fines.
Law 11/2023.
Ordonnance 2023-859.
Implementatiewet. Up to 10% of turnover.
What EAA-Report guarantees and what it doesn't
EAA-Report generates a document structured under Art. 13.2 of Directive (EU) 2019/882 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as the service provider or software vendor.
We guarantee that the document structure follows Art. 13.2 of Directive (EU) 2019/882 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
EAA-Report is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
FAQ — E-signature and identity verification
We only sell to banks (B2B). Does the EAA apply?
Does the report cover video ID verification?
Our widget is embedded via iframe. Who is responsible?
One report for all deployments?
15 minutes?
Certified audit?
⚠️ Important notice: EAA-Report is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. EAA-Report does not replace a qualified professional assessment.
Official legal sources
- Directive (EU) 2019/882 — European Accessibility Act — full text