Why the directive reaches exporters outside the EU
Any company placing covered products on the EU market, or providing covered digital services to EU consumers, is an economic operator under the directive — regardless of where the company is registered. Turkish manufacturers, UAE brand owners, Saudi D2C operators, Qatari retailers, Israeli SaaS companies, Jordanian IT services firms: if your deliverable reaches an EU consumer, the directive attaches.
This is the same scope rule that brought CE marking to Turkish manufacturers in 1995 when the EU-Turkey Customs Union entered into force, and the same rule that brought GDPR to every Middle East brand that opened a European sales channel after 2018. The machinery is familiar. The technical annex is new.
This is not a new category of regulation — it’s the next directive
Every EU product directive in the last twenty years has followed the same legal shape: essential requirements, harmonised technical standard, declaration of conformity, technical documentation, market surveillance. The European Accessibility Act plugs into exactly that framework. The CE mark still applies to covered products. The harmonised standard used to presume conformity is EN 301 549 V3.2.1, which incorporates WCAG 2.1 Level AA. The assessment structure for services follows the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882.
CE marking directives (RoHS, REACH, WEEE, GPSR…)
Essential requirements → harmonised standard → declaration of conformity → technical file → market surveillance. The same shape you’ve filed a hundred times.
European Accessibility Act (Directive 2019/882)
Essential accessibility requirements → EN 301 549 V3.2.1 (WCAG 2.1 AA) → structured self-assessment → 9-page PDF → market surveillance. Only the technical annex is new.
If you already run CE compliance inside your company — and any serious Middle East or Turkish exporter to the EU does — the machinery is familiar. The only genuinely new element is the technical annex: accessibility criteria instead of electrical safety, mechanical safety or chemical substance thresholds.
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 shaping European compliance this year
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
We export from Turkey under the Customs Union. Does that change our position under the European Accessibility Act?
We’re a Gulf-based brand, not a Turkish manufacturer. Is this page still relevant for us?
Our Turkish company already uses EN 301 549 for domestic accessibility requirements. Isn’t that the same thing?
We have three distinct service lines serving EU consumers. Do we need three reports?
Can an accessibility overlay solve this for us?
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.