What reaches an Indian SaaS company and what doesn’t
Directive (EU) 2019/882 targets services provided to consumers in the EU. Pure B2B SaaS not offered to the general public is outside the direct services scope of the directive. For most Indian SaaS companies this means direct regulatory exposure is limited to:
- Consumer-facing surfaces you operate directly (marketing website, sign-up flow, free trial, public knowledge base, public-facing support portal)
- Services delivered to EU consumers where the SaaS product is consumer-facing in the customer journey
Everything else reaches you indirectly — through EU enterprise customers who are directly regulated and cascade the requirement through contract addenda, vendor questionnaires and renewal conditions. The document you need is the same in both cases: an accessibility statement following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882.
Your GDPR response was portable. Your ADA work was too. This is too.
When GDPR landed, the accessible SaaS teams that handled it well were the ones who treated it as a document-layer problem on top of already-good data practice, not as a ground-up security overhaul. The ones that panicked hired consultants at six-figure rates. The EAA is structurally the same problem with a different document output.
If your SaaS already does WCAG 2.1 AA work for ADA reasons (and most Indian SaaS selling to US enterprises does, by now), the underlying accessibility knowledge is portable. What is not portable is the wrapper: European legal references, the harmonised statement format, country-specific enforcement data, Annex V non-accessible content declaration. EAA-Report is the wrapper. Your team does not re-learn accessibility — they re-package what they already know into the document the European customer will accept.
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 — 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.
Enforcement reality your EMEA customer reads every week
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
We are a pure B2B SaaS headquartered in India. Does the EAA directly regulate us?
We already publish a VPAT and a GDPR DPA on our trust center. Why isn’t that enough for European customers?
Our engineering team already runs automated accessibility scans. Is that the same as this document?
We have 60 European enterprise customers across 15 EU countries. How do we scale?
What about Indian government data localisation rules? Do they affect our EAA response?
Is EAA-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.