Why EU law reaches a brand headquartered in Dubai
Applies to economic operators providing covered services to consumers in the EU, regardless of where those operators are established. Your headquarters in the DIFC, in KAFD, in West Bay or in Msheireb remains exactly where it is. The regulatory exposure comes from the European side of the customer journey.
When a cosmetics brand from Dubai opens its online store in Spain, a fashion brand from Doha launches a flagship e-commerce operation in Italy, or a Saudi D2C brand runs a marketing funnel targeting German consumers, the directive attaches to those services. The scope rule is familiar to every compliance team that expanded into Europe in the last decade. GDPR worked the same way in 2018 — by market, not by headquarters. The EAA is the next directive landing on the stack.
This applies to every GCC country — and every country not listed too:
UAE
Saudi Arabia
Qatar
Bahrain
Kuwait
Oman
The GDPR parallel your team already handled
GCC brands that expanded into European markets after 2018 already know this shape. GDPR forced the compliance team to map data flows, publish privacy notices, draft Standard Contractual Clauses, manage data processor agreements and keep documentation on file for the supervisory authority. The EAA uses a similar mechanism for a different regulatory axis:
Map the scope
Which of your digital services reach EU consumers, which products fall under the directive.
Document the self-assessment
Following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882.
Publish the statement
On the service you deliver to European consumers.
Maintain and refresh
Annually or whenever the service changes materially.
The muscle memory is portable. What is new is the output document: an accessibility statement structured under the European harmonised model, citing Directive (EU) 2019/882 as the legal basis and EN 301 549 V3.2.1 as the technical standard.
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 + 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, national transposition law, exact fine range for your primary EU market.
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.
Country-specific enforcement data for Germany, Spain, France, Italy and the Netherlands. One PDF covers all 27 Member States.
Enforcement reality — the cases your European legal team is already tracking
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 with CENTAC and OADI confirming 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). 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 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. |
| EAA-Report | €149, one-time | 9-page PDF, 15 min, European harmonised model adapted to Directive 2019/882, yours forever |
Multiple brands or service lines? Volume pricing for 10+ reports.
GCC and Middle East groups with multiple European brand operations often need 5, 10 or 20 reports — one per brand, one per service line, one per EU market. We offer pack pricing for 10 or more reports. Tell us how many you need and we’ll send a quote within one business day.
Request Volume PricingFrequently asked questions
Our headquarters is in Dubai. Is the European Accessibility Act really a concern for us?
We’re micro by GCC standards but we have 30 employees and €8 million in annual revenue. Does the micro-enterprise exemption help us?
How does this compare to the GDPR work we did when we opened our European operations?
We have three brands in our group, each with a separate European e-commerce operation. Do we need three reports?
Can we use an accessibility overlay instead?
Is EAA-Report 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.