The legal chain you already know
The European Accessibility Act is Directive (EU) 2019/882. Like every other New Legislative Framework directive you've filed under, it operates through four linked obligations:
Essential requirements
The accessibility criteria products and services must meet — defined in Annex I of the directive.
Harmonised technical standard
EN 301 549 V3.2.1, which incorporates WCAG 2.1 Level AA for digital interfaces. Compliance creates a presumption of conformity with the essential requirements.
Declaration of Conformity and CE marking
For products in scope, the manufacturer must draw up an EU Declaration of Conformity and affix the CE mark before placing the product on the market.
Technical documentation and market surveillance
The file must be kept and produced on request to national market surveillance authorities. Five-year retention obligation.
If you've filed a CE Declaration of Conformity for a low-voltage toy or a RoHS declaration for an electronic component, you've already used this exact machinery. The only part that is genuinely new is the technical annex: accessibility criteria instead of electrical safety or substance thresholds.
Which products need the CE mark under the EAA
The directive lists specific product categories that must carry the CE mark under the EAA:
If your factory produces any of these for the EU market, the CE marking obligation now includes accessibility. A product can already carry CE marks for electrical safety, EMC, RoHS and radio equipment — the EAA assessment now folds into the same technical file.
What goes in the technical file — and what EAA-Report delivers
The technical file for an EAA product or service must document the assessment of conformity with the accessibility requirements. The format follows Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882. EAA-Report generates a 9-page PDF following the European harmonised model:
Cover page
Global compliance score, country-specific enforcement data, unique verification reference.
Scope of assessment and evaluation method
What was evaluated, how, and the method of assessment under the harmonised model.
Compliance status by WCAG principle + criterion-by-criterion evaluation
All 17 WCAG 2.1 Level AA criteria with Yes / Partial / No / N/A status across Perceivable, Operable, Understandable, Robust.
Official W3C remediation guidance
Per failed or partial criterion, extracted from "Understanding WCAG 2.1" — not generic advice.
Non-accessible content declaration
Under Annex V of Directive 2019/882.
Feedback mechanism and enforcement procedure
Competent national authority, applicable national transposition law, fine range for your service country.
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 is already live
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. The infringement persisted after a previous 2016 sanction for the same matter.
Fine for accessibility failures on endesaclientes.com after a CERMI complaint with CENTAC and OADI technical reports.
Summoned before the Tribunal Judiciaire de Paris on 12 November 2025 by ApiDV and Droit Pluriel over inaccessible online grocery services. Prior formal notice issued 7 July 2025.
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 in the EU.
"There are free accessibility statement generators. Why pay €149?"
Free generators hand you a blank one-page template. They do not evaluate your service against the 17 WCAG 2.1 AA criteria. They do not cite the W3C's official remediation guidance for your specific failures. They do not include country-specific enforcement data. They do not follow the European harmonised model of Commission Implementing Decision (EU) 2018/1523. EAA-Report does all of that. 9 pages, 15 minutes, €149 one-time. Yours to keep.
| Alternative | Cost | What you actually get |
|---|---|---|
| Manual accessibility audit by a consultancy | €2,000 – €5,000 | Thorough, but weeks of lead time |
| Annual SaaS compliance subscription | €500 – €2,000 / year | Recurring cost, often US-focused |
| Accessibility overlay (legally discredited) | €490 – €1,990 / year | Not a defence. FTC penalised accessiBe $1M for this. |
| EAA-Report | €149, one-time | 9-page PDF, 15 minutes, European harmonised model adapted to Directive 2019/882, yours forever |
Need multiple reports? One PDF per brand, per listing, per country.
Compliance managers often need 10, 20 or 30 reports at once — one per brand, one per ASIN family, or one per EU marketplace. We offer volume pricing on packs of 10 or more reports. Tell us how many you need and we'll send a pack quote within one business day.
Request Volume PricingFrequently asked questions
Do all products under the EAA need a CE mark?
Our products already carry CE marks for LVD, EMC and RoHS. Does the EAA require a separate mark or a separate file?
Does compliance with EN 301 549 create a presumption of conformity?
How long must the technical file be kept?
Can an accessibility overlay count as part of the technical documentation?
Is EAA-Report a certified third-party audit?
⚠️ Important notice: All enforcement cases cited are sourced from identified public documentation. EAA-Report is a structured self-assessment tool, not legal advice and not an overlay.