The EAA does NOT regulate the insurance sector. Article 3.18 lists specific financial services — insurance is not among them. The obligation applies to your website as an e-commerce channel under Art. 2.2(f). Your actuarial models, policy wording and claims processes are not covered. Your online sales interface is.
The distinction that matters: sector vs channel
Many insurance compliance teams search for "insurance EAA" and find nothing in the Directive's financial services definition. They conclude they are exempt. This is incorrect. The Directive approaches accessibility through two paths: sector-specific (banking, transport, telecoms) and channel-specific (e-commerce). Insurance is not in the sector path. But the moment an insurer sells policies online to consumers, the channel path applies.
This matters for compliance budgeting: the assessment scope is your website and quoting/purchase flow, not your entire insurance operation.
What the EAA requires from your insurance website
Quote request form
Labels, error identification, keyboard navigation. WCAG 1.3.1, 3.3.1, 2.1.1.
Coverage customisation UI
Sliders, toggles, plan comparisons must be operable without mouse. WCAG 2.5.1, 4.1.2.
Online payment flow
Card input, confirmation, error handling. WCAG 3.3.4 for financial transactions.
Policy document download
PDF policies must have text layer, not flat images. WCAG 1.1.1.
What you receive
Cover page
Compliance score, verification reference, date.
Service identification and scope
Product, deployment context, evaluation method, legal framework.
17 WCAG 2.1 AA criteria
Criterion-by-criterion evaluation across four principles.
W3C remediation guidance
Actionable fixes per failed criterion.
Accessibility statement
Following Annex V of Directive 2019/882.
Legal basis and scope disclaimer
Directive 2019/882, EN 301 549 V3.2.1, national transposition law.
Generated in your browser.
What it costs
Three mistakes insurers make
"Insurance is not in the EAA"
Not as a sector. But your website selling policies online IS e-commerce under Art. 2.2(f). The channel, not the sector, triggers the obligation.
Flat image PDFs delivered as policy documents
If the policy document is a rasterised image inside a PDF wrapper, users with screen readers cannot read their own policy. WCAG 1.1.1.
CAPTCHA without audio alternative on the quote request page
Visual CAPTCHAs without accessible alternatives exclude users with visual disabilities from even requesting a quote.
Enforcement
BFSG. Per-infringement fines.
Law 11/2023.
Ordonnance 2023-859.
Implementatiewet. Up to 10% of turnover.
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. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case.
EAA-Report is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Frequently asked questions — Insurance websites
Is insurance covered by the EAA?
What is the scope?
Are PDF policies in scope?
Microenterprise exemption?
15 minutes?
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