European Enterprise Client EAA Requirement

Q: Our EU customer added a compliance clause. Are we obliged as B2B SaaS?

The directive targets services to consumers so most pure B2B SaaS is not directly obliged. But the contract clause is a contractual obligation once signed. The practical requirement is the same document either way.

Q: Is the document they want a VPAT?

No. The European harmonised accessibility statement (Decision 2018/1523) is a different instrument from the VPAT. Deliver the European format as the primary document.

What "EAA requirement" means in a contract review

When your European enterprise customer's compliance team reviews your vendor file, they're looking for the same shape of document they hold for themselves. They are obliged, they have the document, they expect their vendors to have a comparable one. For accessibility, the comparable document follows the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882. It isn't optional, it isn't flexible, and it isn't a VPAT.

The clause they add to your contract usually cites Directive (EU) 2019/882 as the legal basis and asks you to maintain a current accessibility statement aligned with the harmonised format, updated periodically, with a feedback mechanism and enforcement authority reference. That's the ask. EAA-Report produces exactly that document.

ADA parallels help — up to a point

If you've handled ADA Title III exposure, the EAA is familiar in spirit. Both frameworks target digital accessibility, both point at WCAG as the de facto technical benchmark, both are enforced through fines and civil actions, both have spawned an industry of overlay vendors that courts and regulators have rejected. The EAA diverges on three practical points:

Divergence 1

Technical standard

EN 301 549 V3.2.1 is the European harmonised standard, not Section 508. It incorporates WCAG 2.1 AA for web content and adds requirements for non-web ICT.

Divergence 2

Document format

The European harmonised accessibility statement follows the European harmonised model of Decision (EU) 2018/1523 (adapted to the scope of Directive 2019/882), not the Information Technology Industry Council's VPAT template.

Divergence 3

Enforcement structure

Each EU member state has its own competent authority and its own fine range, driven by the national transposition of the directive.

Your team already knows the WCAG part. EAA-Report wraps that knowledge into the European format your customer expects.

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.

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

Our European customer added a clause saying we must 'comply with the European Accessibility Act'. Are we legally obliged if we're a pure B2B SaaS vendor?

The directive itself targets services to consumers, so most pure B2B SaaS is not directly obliged. But the contract clause is a contractual obligation separate from the directive — once you sign, you're contractually bound to deliver what the clause asks for. The practical requirement is the same document either way.

Can we push back on the clause and remove it from the contract?

You can try. Most enterprise customers will refuse because their own compliance team mandates the flow-down. Delivering the document is usually faster than negotiating removal.

Is the document they want a VPAT or something else?

Something else. The European harmonised accessibility statement follows the European harmonised model of Commission Implementing Decision (EU) 2018/1523 (adapted to the scope of Directive 2019/882) and is a different instrument from the VPAT/ACR. Some customers accept a VPAT as supplementary, but the primary deliverable they want is the European format.

We already do WCAG 2.1 AA work internally. Is this report just repackaging what we already know?

In part, yes — and that's the value. The accessibility knowledge is portable, the wrapper isn't. You save the weeks your team would otherwise spend researching the European legal references, the Commission decision, the country-specific authorities and the statement format.

Can this be used for multiple European customers or do we need one per client?

One statement can cover your service across multiple customers in the same market. If your customers span multiple EU countries and specifically want their country's authority referenced, you may want one report per primary market.

Is this a certified third-party audit we can submit to a regulator?

No. It is a structured self-assessment following the European harmonised model, generated from the data you provide under your own responsibility. Self-assessment is what the EAA framework expects and what your customer is asking for — third-party audits are an optional higher bar.

⚠️ 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.

Your European Enterprise Client Added an EAA Requirement to the Contract. Here's the Document They Actually Want.