The EAA → EN 301 549 → WCAG 2.1 AA chain
Directive (EU) 2019/882 sets the essential accessibility requirements for products and services. It does not write the technical detail directly — like every other New Legislative Framework directive, it delegates the technical criteria to a harmonised European standard. That standard is EN 301 549 V3.2.1, published by ETSI / CEN / CENELEC and formally cited in the Official Journal of the EU.
EN 301 549 incorporates WCAG 2.1 Level AA as the conformance target for web content. So when Amazon Seller Central says your listing must be accessible under the EAA, what that means in practice is: your listing must conform to the applicable WCAG 2.1 AA criteria, and you must have a documented assessment of that conformance.
The 17 criteria evaluated in your report
WCAG 2.1 AA contains 50 success criteria organised under four principles. For most e-commerce product pages and listings, 17 of those criteria are the ones that actually apply and that get evaluated in the EAA-Report assessment. For each criterion, the report records one of four status values — Yes, Partial, No, N/A — and for every failed or partial criterion, the report attaches the official W3C remediation guidance from the "Understanding WCAG 2.1" documentation.
Perceivable
Text alternatives, colour contrast, captions. Can users see or hear all content?
Operable
Keyboard navigation, focus visibility, no keyboard traps. Can users interact without a mouse?
Understandable
Consistent navigation, error identification, labels and instructions. Is content predictable and clear?
Robust
Compatible name, role, value for custom components. Does the content work with assistive technologies?
What's in the 9-page PDF
Cover page
Global compliance score, country-specific enforcement data, unique verification reference.
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 by principle.
Official W3C remediation guidance
Per failed or partial criterion, extracted from "Understanding WCAG 2.1" — not a consultant's opinion.
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 service country.
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 — four cases to know
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 for accessibility failures on endesaclientes.com. CENTAC and OADI technical reports confirmed failure to meet WCAG Level AA — the same conformance target under the EAA today.
Summoned before the Tribunal Judiciaire de Paris on 12 November 2025 over inaccessible online grocery services.
Civil penalty for deceptive overlay claims, final consent order 22 April 2025 (Docket C-4817). The FTC specifically criticised failure to make basic components (menus, headings, tables, images) accessible. Overlays are not a substitute for a real WCAG assessment.
"Why not pay a consultant for a full WCAG audit?"
You can, and if you run a large e-commerce operation with complex custom interfaces, a full manual audit at €2,000-€5,000 is a legitimate option. For a standard Amazon product listing or brand storefront page that needs a documented self-assessment on file under the EAA, you don't need a consultant opinion — you need the structured assessment document in the European harmonised format, which is a defined output, not a creative exercise. EAA-Report produces that exact document for €149. One afternoon of a compliance manager's time, not a three-week consulting engagement.
| 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 minutes, European harmonised model adapted to Directive 2019/882, yours forever |
Need multiple reports? One PDF per brand, per listing, per country.
Compliance managers often need 10, 20 or 30 reports at once — one per brand, one per ASIN family, or one per EU marketplace. We offer volume pricing on packs of 10 or more reports. Tell us how many you need and we'll send a pack quote within one business day.
Request Volume PricingFrequently asked questions
Does the EAA require WCAG 2.1 AA specifically, or just "accessible"?
Why only 17 criteria instead of all 50 in WCAG 2.1 AA?
Is this an automated scan like aXe, Lighthouse or WAVE?
Does Amazon accept this WCAG 2.1 AA report?
How long does it take to answer the 17 questions?
Can an accessibility overlay make my listing WCAG 2.1 AA compliant?
⚠️ 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.