What the VPAT actually is — and why it doesn't answer the European question
The VPAT (Voluntary Product Accessibility Template) was created by the Information Technology Industry Council for US federal procurement under Section 508. When completed, it becomes an Accessibility Conformance Report (ACR). It documents how a product conforms with US accessibility standards — Section 508 revised, and optionally WCAG 2.0 or 2.1. It is the default document US SaaS vendors ship to enterprise customers running ADA-aware procurement.
The European Accessibility Act takes a different path. The text of Directive (EU) 2019/882 does not reference VPATs or Accessibility Conformance Reports as a required document, does not prescribe the VPAT format, and does not mandate an ACR. The directive references EN 301 549 V3.2.1 as the harmonised technical standard and the European harmonised model of Commission Implementing Decision (EU) 2018/1523 (adapted to its scope) as the structure for the accessibility statement. Different instrument. Different format. Different structure.
- Created by ITI for Section 508 procurement
- References WCAG 2.0 or 2.1 optionally
- 500-row spreadsheet format
- Required for US federal contracts
- Accepted by many US enterprise buyers
- Not mentioned in Directive (EU) 2019/882
- Published by the European Commission
- References EN 301 549 V3.2.1 + WCAG 2.1 AA
- 9-page structured PDF
- Required under Directive (EU) 2019/882
- What EU enterprise procurement asks for
- Different instrument — not interchangeable with VPAT
What your European customer is actually asking for
When an enterprise client in Germany, France, Italy, Spain or the Netherlands asks for "your EAA accessibility statement", what they mean is a document structured following the European harmonised model of Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882 — a structured statement covering scope, compliance status by WCAG principle, criterion-by-criterion evaluation, non-accessible content under Annex V of Directive 2019/882, a feedback mechanism, and a reference to the competent national authority. Not a VPAT spreadsheet. Not a one-paragraph marketing statement. The specific European harmonised format. EAA-Report generates exactly that document as a 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 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.
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.
Why your existing VPAT isn't a translation exercise
Compliance managers who have already filed a VPAT often ask whether the ACR can simply be re-labelled for European customers. It can't. The VPAT and the European harmonised accessibility statement are different documents that evaluate different technical standards against different regulatory frameworks. EN 301 549 V3.2.1 is not a rebrand of Section 508 — it's a European standard that references WCAG 2.1 but structures conformance differently and has its own scope regarding non-web ICT.
The practical outcome is that ship-ready US SaaS vendors with a clean ACR still need a second, European-specific document to satisfy procurement in the EU. EAA-Report produces that second document in 15 minutes from the same underlying accessibility knowledge your team already has.
Enforcement is live, and it's not just public sector
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 over inaccessible online grocery services.
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?"
Free generators produce a one-paragraph marketing statement. They don't follow the European harmonised model of Commission Implementing Decision (EU) 2018/1523 adapted to Directive 2019/882, don't evaluate WCAG criteria, don't identify the competent national authority. EU enterprise procurement has seen them before and marks the questionnaire row incomplete. The 9-page PDF passes the format check.
| 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.
Request Volume PricingFrequently asked questions
Does the European Accessibility Act require a VPAT?
Our ACR already covers WCAG 2.1 AA. Isn't that the same thing as EN 301 549?
If I deliver a VPAT to a European customer, will they accept it?
Can we use an accessibility overlay to cover both the US and EU requirements at once?
Is the 9-page PDF a certified third-party audit?
How long does it take to generate the EAA accessibility statement?
⚠️ 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.