We are pure B2B SaaS. Does the EAA apply to us directly?

Probably not directly. Pure B2B services not offered to the general public are outside the services scope. But your marketing website and sign-up flow are usually consumer-facing surfaces that bring you back in scope. And EU enterprise customers will cascade the requirement contractually.

If the directive does not apply directly, why generate a statement?

Because your European enterprise customer is going to ask for it before signing, before renewal, or during a vendor security questionnaire. Not having the document costs you deals.

European Accessibility Act for B2B SaaS Vendors

What the directive actually says about B2B

Directive (EU) 2019/882 defines its services scope around services “provided to consumers”. Pure business-to-business services that are not offered to the general public fall outside the services-specific obligations of the directive. In plain English: if your SaaS is sold only to enterprises, through direct sales, with no consumer sign-up and no consumer-facing interface, the directive itself does not directly oblige you.

That is the good news. The limited news is that it only removes one layer of exposure. Three other layers are still live.

Three layers that still pull B2B SaaS in

Layer 1

Consumer-facing surfaces

Most B2B SaaS vendors also operate marketing websites, sign-up flows, knowledge bases, help centers, trial accounts and webinars. Those surfaces are consumer-facing and fall under the services scope of the directive for companies above the micro-enterprise threshold.

Layer 2

Flow-down from your enterprise customer

Your EU enterprise customer is directly regulated. They cascade the requirement through contract clauses, DPA addenda, vendor security questionnaires and renewal conditions. The deliverable they ask for is an accessibility statement in the European harmonised format.

Layer 3

Product hardware — no exemption

The directive's service-related micro-exemption and the consumer-services scope are separate from product obligations. If your platform ships any hardware component or e-reader-like software into the EU, product obligations apply regardless of size or B2B status.

What the 9-page PDF contains

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.

3–4

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.

5–6

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

🇪🇸

Vueling — Spain, sentence Feb 2024

€90,000

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.

🇪🇸

Endesa — Spain, 2018

€30,001

Fine after a CERMI complaint. CENTAC and OADI technical reports confirmed failure to meet WCAG Level AA.

🇫🇷

Auchan, Carrefour, E. Leclerc, Picard Surgelés — France, November 2025

Pending

Four supermarket giants summoned before the Tribunal Judiciaire de Paris on 12 November 2025 by ApiDV and Droit Pluriel over inaccessible online grocery services.

🇺🇸

FTC vs accessiBe — April 2025

$1,000,000

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.

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Frequently asked questions

We're pure B2B SaaS. Does the EAA apply to us directly?

Probably not directly — the services obligations of Directive (EU) 2019/882 target services provided to consumers, and pure B2B services not offered to the general public are outside that scope. But your marketing website, sign-up flow, support portal and knowledge base are usually consumer-facing surfaces that bring you back into scope at least partially. And your EU enterprise customers will cascade the requirement contractually regardless.

If the directive doesn't apply directly, why would we bother generating a statement?

Because your European enterprise customer is going to ask for it before signing, before renewal, before onboarding, or during a vendor security questionnaire. Compliance managers in EU banks, insurers, hospitals, universities and government-adjacent organisations are already baking this into procurement. Not having the document costs you deals.

Our SaaS doesn't have hardware or e-readers. Does that help?

It means you're clear of the product obligations of the directive, which simplifies one layer. The services analysis still applies to your consumer-facing surfaces and to the flow-down pressure from enterprise customers.

Is the EAA enforced against B2B vendors directly?

Enforcement actions so far have targeted service providers directly obliged under the directive — airlines, utilities, supermarkets, banks, telcos. B2B SaaS vendors are rarely the direct target of a fine, but they are routinely the target of a cancelled deal or a failed renewal when they can't produce the document their customer is asking for.

Can we just say 'we comply with WCAG 2.1 AA' in our security portal and skip the PDF?

Some customers will accept that. Many will not, because enterprise procurement specifically filters for a statement referencing Directive (EU) 2019/882 and structured following the European harmonised model of Decision (EU) 2018/1523 adapted to its scope. Ship the 9-page PDF and you cover both groups.

Is this report a legal opinion on whether we're in scope?

No. It is a structured self-assessment of your service against WCAG 2.1 AA through the European harmonised model, generated from the data you provide. It is not legal advice. For a legal opinion on whether your specific B2B SaaS is in scope of the directive, consult your own counsel.

⚠️ 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.

The European Accessibility Act and B2B SaaS Vendors: The Honest Breakdown and What You Actually Have to Deliver