The regulatory stack Indian exporters to the EU now carry
Indian compliance teams serving European customers are not new to extraterritorial EU regulation. The stack has been growing since 2018:
Each item in the stack operates on the same logic: apply by market, cascade through contracts, maintain documented compliance, refresh annually. The EAA plugs into the stack at the document layer. For compliance teams already running a GDPR cascade, adding the EAA is workflow extension, not workflow reinvention.
What the minimum deliverable actually is
When a European customer sends a contract clause or a vendor questionnaire referencing Directive (EU) 2019/882, the minimum deliverable is a documented accessibility statement following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882. Not a VPAT, not a GDPR DPA clone, not a one-paragraph marketing blurb. A structured statement with:
- Scope of the service assessed
- Compliance status by WCAG principle (fully, partially, or non-compliant)
- Criterion-by-criterion status against the 17 applicable WCAG 2.1 Level AA criteria
- Non-accessible content declared under Annex V of the directive
- Feedback mechanism and contact details
- Reference to the competent national authority for the customer’s country
- Evaluation date and method
- Legal basis citations
EAA-Report generates all of the above as a 9-page PDF. One per service line, 15 minutes per document, per customer or per market depending on how the cascade is structured.
Why India-specific consultancies charge 10–50× for the same document
BarrierBreak, Pivotal Accessibility, and a handful of other India-based accessibility consultancies offer enterprise-grade manual audits, VPAT generation and EAA compliance engagements. Their pricing reflects the value of manual expert audit work: typically several thousand euros per engagement, sometimes tens of thousands for large portfolios. That level of engagement is appropriate when a customer specifically demands an independent third-party audit or when your service has complex custom interfaces that warrant deep expert review.
For the documented self-assessment that the EAA framework actually requires as the baseline — the one your European customer’s procurement team is asking for in the vendor questionnaire — a manual audit is overkill. EAA-Report produces the structured self-assessment at €149 per report, 15 minutes per document, with pack pricing for portfolio cascades. The expensive audit and the €149 report coexist: they answer different questions.
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.
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 an Indian company with no physical EU presence. How does the EAA reach us?
Does this apply to our India-only product that happens to have one German customer?
We handle EAA as part of a broader European compliance programme — should each team own its own documents?
How do we integrate this into our existing SOC 2 / ISO 27001 annual refresh cycle?
Our customers span UK, EU, Switzerland and EEA countries. Does the EAA cover all of them?
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.