Why the free generators look cheap but cost you the deal
Free accessibility statement generators are designed for a different job. Their use case is: small business owner, new website, wants a compliance-looking statement in the footer for cosmetic coverage of ADA exposure. For that job they are fine. For shipping a document to a European enterprise procurement team as part of a vendor security review, they are not.
The difference is that the generator output has no evaluation, no criterion-by-criterion status, no non-accessible content declaration under Annex V of Directive 2019/882, no competent authority reference, no legal basis citations and no structured compliance status under the four WCAG principles. The procurement analyst reviewing your statement has filed a hundred of them this year — she can tell the difference between a generic one-paragraph template and a proper harmonised statement within three seconds. When she marks your row incomplete, you're back at the start of the queue, probably delayed past the go-live.
What the harmonised format actually contains — and what EAA-Report delivers
EAA-Report generates a 9-page PDF following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882:
Cover page
Global compliance score, country-specific enforcement data, unique verification reference (EAA-XXXXXXXX).
Service owner identification, scope and evaluation method
Under the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882.
Compliance status by WCAG principle + criterion-by-criterion evaluation
All 17 WCAG 2.1 AA criteria with Yes / Partial / No / N/A across Perceivable, Operable, Understandable, Robust.
Official W3C remediation guidance
Per failed or partial criterion, extracted from "Understanding WCAG 2.1" — real fixes, not generic advice.
Non-accessible content declaration
Under Annex V, Directive 2019/882.
Feedback mechanism and enforcement procedure
Competent national authority for your service country, applicable national transposition law, exact fine range.
Legal basis
Directive (EU) 2019/882, the European harmonised model of Decision (EU) 2018/1523 (adapted to the scope of Directive 2019/882) and EN 301 549 V3.2.1.
Three SaaS-specific gotchas to know before you answer the questionnaire
Your trial and marketing surfaces are consumer-facing
Even a pure B2B SaaS with no consumer product usually has a marketing site, a sign-up flow, a free trial and a public-facing knowledge base. Those surfaces are in scope under the services definition.
Third-party components are your responsibility in the statement
If your product embeds a third-party chatbot, analytics widget, payment form or live-chat widget, you are still responsible for declaring the accessibility status in your statement. The customer won't forward the question to Intercom or Stripe.
Renewal-time re-assessment is standard
Most enterprise customers expect the statement to be updated at least annually. Plan for re-generation on the same cadence as your SOC 2 refresh.
Enforcement reality — the ambient pressure driving your customer's procurement team
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.
"Aren't free generators good enough for most SaaS companies?"
| 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
Aren't free accessibility statement generators good enough for most SaaS companies?
Does our SaaS need a separate statement for each product we sell?
How do we declare known accessibility gaps without killing the deal?
Our product uses an accessibility overlay. Can we still generate a credible statement?
How often do we need to re-generate this document?
Is this report legal advice or a third-party audit?
⚠️ 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.