Why the EAA reaches Istanbul, Ankara and Izmir — the same way GDPR, CE marking and GPSR already do
Turkish exporters are already familiar with EU regulatory reach. CE marking for products, GPSR for general product safety, WEEE for electronics recycling, REACH for chemicals — all of these apply to Turkish companies selling into the EU market. The European Accessibility Act follows exactly the same principle: it applies by market destination. Article 2.2(f) covers e-commerce services provided to consumers in the EU. The Directive does not ask where your company is registered. It asks where your consumer is located.
Turkey's EU candidate status makes this especially relevant. Turkish businesses investing in EU regulatory compliance today are building infrastructure that will become domestic law if accession advances. But even without accession, the commercial reality is immediate: German marketplace operators, French retail chains and Dutch procurement departments are already adding EAA accessibility clauses to supplier contracts. Without documentation, Turkish suppliers lose contract eligibility.
What the EAA requires from your e-commerce web store
Under Article 13.2 of Directive (EU) 2019/882, every provider of a covered service must produce and maintain structured accessibility documentation:
Accessibility Statement
Under Art. 13.2. Must be public, accessible, up-to-date, and include a feedback mechanism.
WCAG 2.1 AA Assessment
17 official criteria grouped by the 4 principles. Harmonised standard EN 301 549.
Remediation plan
Issues documented with priority and fix guidance. The law requires remediation, not just identification.
Feedback mechanism
A public channel for any user to report accessibility barriers. Required as part of the Statement.
What you receive in your 6-10 page PDF
WCAG 2.1 AA Assessment
17 official criteria evaluated with per-principle scoring and numbered WCAG reference.
Personalised Accessibility Statement
Under Art. 13.2. With your company data, website URL, country of service, contact email. Ready to publish.
HTML footer block
Copy-paste code with Accessibility Statement link, feedback mechanism and competent authority data.
Legal risk analysis
Verified fine ranges per country: Germany up to €100K, Spain up to €1M, France up to €250K, Netherlands up to €900K.
Prioritised remediation plan
Each issue with HIGH/MEDIUM priority and W3C guidance. Send it to your dev team.
Disproportionate burden template
Under Annex VI, for partial exemption claims if specific features cannot be made accessible without fundamental alteration.
Generated in your browser. No data leaves your device.
What it costs
Three mistakes Turkish exporters make with EU accessibility compliance
"Turkey is a candidate country — we have a transition period"
Turkey's EU candidate status provides no exemption or transition under the EAA. The Directive applies to any company providing e-commerce services to EU consumers. Candidate status is a political framework; the EAA is a market regulation. It applies today, not when accession negotiations conclude.
"We comply with Turkish Law No. 5378 on disability rights"
Turkish Law No. 5378 (Engelliler Hakkında Kanun) addresses disability rights within Turkey but does not mandate structured web accessibility documentation, WCAG conformance reporting, or published Accessibility Statements. The EAA requires all three for any e-commerce service provided to EU consumers. Turkish domestic compliance does not satisfy EU obligations.
"My German buyer will tell me what format they need"
Some will. Most will simply move to a supplier who already has the documentation. The EAA does not require your buyer to hand you a template — it requires you, as the service provider, to produce your own Accessibility Statement and WCAG evaluation under Art. 13.2. Having it ready before the buyer asks is the difference between winning and losing the contract.
Enforcement is live
The EAA has been enforceable since 28 June 2025. Market surveillance authorities across the EU have started inspections.
BFSG. Up to €100,000 per individual infringement. BFIT-Bund as surveillance authority.
Ordonnance 2023-859. Tribunal Judiciaire de Paris admitted EAA lawsuits against 4 supermarket chains in November 2025.
Implementatiewet. Up to €900,000 or 1-10% of annual turnover. ACM actively auditing banking and telecom since spring 2026.
Law 11/2023 + subsidiary regime RDL 1/2013. Minor up to €30K, serious up to €90K, very serious up to €1M. Repeat offences: operating ban up to 2 years.
What EAA-Report guarantees and what it doesn't
EAA-Report generates a document structured under Art. 13.2 of Directive (EU) 2019/882 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as service provider.
We guarantee that the document structure follows Art. 13.2 of Directive (EU) 2019/882 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
EAA-Report is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Frequently asked questions — Turkish e-commerce exporters
Does the EAA apply to Turkish companies selling to EU consumers?
I sell through Amazon EU, not through my own website. Does the EAA still apply?
Is Turkey classified as high-risk or low-risk under the EAA?
Can I use EAA-Report for multiple web stores?
Is my data safe?
Is EAA-Report legal advice?
⚠️ Important notice: EAA-Report is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. EAA-Report does not replace a qualified professional assessment.
Official legal sources
- Directive (EU) 2019/882 — European Accessibility Act — full text