What reaches you, and what doesn't
The European Accessibility Act directly regulates certain services “provided to consumers” in the EU — e-commerce, consumer banking, passenger transport, e-books, telecoms, audiovisual media. Pure B2B SaaS not offered to consumers is usually outside the direct services scope. So for most US SaaS companies the direct regulatory exposure is limited to:
- Consumer-facing surfaces you operate (marketing site, sign-up flow, trial accounts, support portal, knowledge base)
- Hardware or e-reader software components, if any, shipped to the EU market
- Services you provide to EU consumers directly, if any
Everything else reaches you indirectly, through your EU enterprise customers who cascade the requirement via contract clauses, vendor security questionnaires and DPA amendments. The operational minimum is the document that satisfies both the direct and the indirect exposure with one deliverable.
The operational minimum in three moves
Document the self-assessment
Generate a structured accessibility statement following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882, evaluating your service against the 17 applicable WCAG 2.1 Level AA criteria. EAA-Report handles this in 15 minutes.
Publish it on your trust center
Put the statement where your procurement reviewers look. Alongside your SOC 2 summary and your GDPR DPA.
Have it ready for RFPs
When an EU enterprise customer asks “do you have an EAA accessibility statement?”, the answer is “yes, attached”, not “we're working on it”.
That's the minimum. It's what ships the deal. Anything above that — full manual WCAG audit, independent third-party attestation, remediation engagement — is worth investing in if and when the business case justifies it. For most US SaaS vendors closing their first ten European enterprise deals, the structured self-assessment is what unblocks procurement today.
What's in the 9-page PDF
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.
Enforcement reality
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
We're headquartered in the US and we sell to US customers mostly. Why should we care about the EAA at all?
How is this different from our existing VPAT?
Do we need to hire a consultancy like Deque to do this?
Can we rely on our accessibility overlay for EAA compliance?
How do we handle multiple EU markets with one document?
Is this legal advice or a certified 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.