Why procurement specifically asks for it — and not legal
European procurement teams are the tip of the compliance spear inside large enterprises. By the time a vendor question reaches legal, the procurement team has already filtered the vendor file for the standard set of documents: SOC 2 or ISO 27001 Type II, GDPR DPA, insurance certificates, tax identification, and now the accessibility statement. The statement is a procurement gate, not a legal deep-dive — which means procurement is looking for format match, not legal analysis. They need the structured harmonised document to tick the box and move on. Not delivering it means your onboarding stays stuck in the procurement queue for weeks.
This is why a $6,000 consultancy engagement is overkill for the onboarding deliverable. The procurement gate is a format check: does the vendor have an accessibility statement structured following the European harmonised model of Decision (EU) 2018/1523 (adapted to the scope of Directive 2019/882), referencing Directive 2019/882, with criterion-level status and a feedback mechanism? EAA-Report hands you exactly that format in 15 minutes.
What procurement specifically checks for on your statement
Based on the European harmonised model of Commission Implementing Decision (EU) 2018/1523 (adapted to the scope of Directive 2019/882), procurement reviewers typically verify seven elements:
EAA-Report's 9-page PDF contains all seven elements by default, plus criterion-by-criterion evaluation of the 17 applicable WCAG 2.1 AA criteria with official W3C remediation guidance for each failure.
B2B-specific context procurement will recognise
If you're a B2B SaaS vendor delivering service to an EU enterprise, your statement covers the surfaces you deliver to the customer: the application interface, the administrative console, the end-user experience (when there is one), the API documentation portal, the help center. You are not responsible for accessibility failures on the customer's own public website built on top of your product. Clarifying the scope clearly in the statement is standard and expected. EAA-Report lets you define the scope in the generation flow.
Enforcement reality — why procurement is under pressure
Fine upheld by the Audiencia Nacional Contentious-Administrative Chamber Section 8 in February 2024 (sanction originally imposed October 2020), plus a six-month ban on concurring in proceedings for the granting of official aid.
Fine after a CERMI complaint. CENTAC and OADI technical reports confirmed failure to meet WCAG Level AA.
Four supermarket giants summoned before the Tribunal Judiciaire de Paris on 12 November 2025 by ApiDV and Droit Pluriel over inaccessible online grocery services.
Civil penalty for deceptive overlay claims, final consent order 22 April 2025 (Docket C-4817). UsableNet documented 119 defendants with accessibility widgets sued in May 2025 alone. Overlays are not a legal defence in the US or the EU.
"Free templates exist. Why pay €149?"
| Alternative | Cost | What you actually get |
|---|---|---|
| Manual accessibility audit (Deque, Level Access) | €4,000 – €8,000 | Thorough, 3-week lead time |
| Annual SaaS compliance subscription | €500 – €2,000 / year | Recurring cost, US-focused format |
| Accessibility overlay (legally discredited) | €490 – €1,990 / year | Not a defence in US or EU. FTC penalised accessiBe $1M. |
| EAA-Report | €149, one-time | 9-page PDF, 15 min, European harmonised model adapted to Directive 2019/882, yours forever |
Need multiple reports? One PDF per product, per customer, per country.
SaaS compliance teams often need reports per product line, per EU market or per enterprise customer. We offer volume pricing on packs of 10 or more. Tell us how many you need and we'll send a quote within one business day.
Request Volume PricingFrequently asked questions
Our European customer's procurement team asked for 'your accessibility statement per Directive 2019/882'. Is that the same as a VPAT?
Can we pass procurement by publishing a one-paragraph accessibility statement on our website?
Do we need our statement to be audited by a third party before procurement accepts it?
How long does the statement need to be valid for?
What if our product has accessibility gaps we haven't remediated yet?
Is this report legal advice?
⚠️ Important notice: EAA-Report is a structured self-assessment tool, not legal advice and not an overlay. All enforcement cases cited are sourced from identified public documentation.