What cascading means operationally
A cascade is what happens when a regulatory obligation on a principal flows contractually down through the supply chain to every supplier whose work contributes to the regulated service. Under the European Accessibility Act, the regulated principal is typically the EU service provider delivering the end-user experience — a consumer bank, an insurer, a retailer, a public-sector body. Their accessibility obligation attaches to the whole service, including the components built by third parties.
Vendor management teams close the supply-chain gap by amending contracts. A typical cascade clause reads: “Supplier shall deliver a current accessibility statement conforming with Directive (EU) 2019/882, structured following the European harmonised model of Commission Implementing Decision (EU) 2018/1523 adapted to the scope of Directive (EU) 2019/882, for each service line in scope, refreshed at least annually.” That clause goes out to everyone. Tier-1 implementation partners, tier-2 offshore dev shops, tier-3 niche SaaS vendors. One clause, fifty vendors, one deliverable per vendor — that is the cascade.
Why it works the same as GDPR did
The cascade mechanism is identical to how GDPR Article 28 obligations flowed through the supply chain from 2018 onward. Every SaaS vendor, every managed service provider, every offshore development partner ended up with a data processor agreement in their contract inbox during that year. The EAA cascade uses the same legal mechanism — the contract amendment — and the same operational response: accept the clause, produce the document, maintain it, refresh it annually.
The compliance teams that ran the GDPR cascade in 2018 already know the shape. EAA-Report is the document that plugs into the shape.
What each document in the cascade must contain
EAA-Report generates a 9-page PDF per service line following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882, containing:
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 — Commission Implementing Decision (EU) 2018/1523.
Compliance status + 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.
Why cascades are moving fast this quarter
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.
Civil penalty for deceptive overlay claims, final consent order 22 April 2025 (Docket C-4817). 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 (BarrierBreak, Deque, Level Access) | €4,000 – €8,000 | Thorough, 3-week lead time — right for third-party audit demands, overkill for cascade documentation |
| 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 — pack pricing for portfolios |
Portfolio pricing for 10+ reports
For large European customer portfolios requiring 10, 20, 50 or more accessibility statements, we offer pack pricing with volume discounts. Tell us the size of your cascade and we'll reply within one business day.
Request Portfolio PricingFrequently asked questions
How many documents does a typical cascade across 30–50 European clients actually produce?
Can one document cover multiple clients?
How do we manage the annual refresh without re-running the full process every year?
Who signs off on each document internally — compliance, legal, engineering?
What if our cascade hits a service line we have not WCAG-tested yet?
Is this document a certified 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.