Framework — EAA
Accessibility is a supply chain obligation
The European Accessibility Act makes every economic operator responsible — manufacturers, importers, and distributors. If you build, sell, or distribute digital products in the EU, accessibility is your obligation.
Key articles
Obligations across the supply chain
The EAA assigns specific obligations to each economic operator in the supply chain. Your role determines what you must verify, document, and monitor.
Article 7
Obligations of manufacturers
Manufacturers must design and produce products that meet accessibility requirements. When using third-party components, they must ensure those components don't compromise accessibility.
Article 9
Authorised representatives
Manufacturers outside the EU must appoint an authorised representative. The representative carries obligations for accessibility compliance on the manufacturer's behalf.
Article 11
Obligations of importers
Importers must verify that manufacturers have carried out accessibility assessments. They must ensure products entering the EU market meet Annex I requirements.
Article 14
Obligations of distributors
Distributors must verify that third-party products and components meet accessibility requirements before making them available on the market. This includes verifying CE marking and documentation.
Economic operators
Which role are you?
The EAA uses "economic operators" as the umbrella term for everyone in the supply chain. Your obligations depend on your role — manufacturer, importer, or distributor.
Manufacturer
Natural or legal person who manufactures a product, or has a product designed or manufactured, and markets it under their name or trademark.
If you build SaaS and sell it under your brand, you're the manufacturer. You're responsible for accessibility of your product — including third-party components you embed.
Importer
Natural or legal person established in the EU who places a product from a third country on the EU market.
If you resell or distribute non-EU SaaS products in the EU market, you may be the importer. You must verify the manufacturer has done their accessibility homework.
Distributor
Natural or legal person in the supply chain, other than the manufacturer or importer, who makes a product available on the market.
MSPs, resellers, and platform integrators who distribute third-party software. You must verify accessibility before making products available to your customers.
Terminology
The EAA's vocabulary
The EAA borrows product safety language and applies it to accessibility. Understanding these terms helps you navigate obligations and communicate with auditors.
Economic operator
The umbrella term for all entities in the supply chain — manufacturer, authorised representative, importer, and distributor. Each has distinct accessibility obligations under the EAA.
Annex I requirements
The accessibility requirements products and services must meet. For digital services, this maps to WCAG 2.2 Level AA — perceivable, operable, understandable, and robust.
Conformity assessment
The process of verifying that a product meets accessibility requirements. Manufacturers can self-assess following Annex IV procedures.
CE marking
The marking that indicates a product meets EU requirements. For the EAA, CE marking means the product has passed accessibility conformity assessment.
Market surveillance
National authorities monitor products on the market for compliance. Non-accessible products can be withdrawn — and economic operators can face penalties.
Disproportionate burden
Article 14 allows limited exceptions when accessibility requirements impose a disproportionate burden. But the burden must be documented and reassessed periodically.
How Sudory helps
Accessibility compliance, continuously
The EAA requires ongoing conformity — not one-time audits. Sudory scans continuously, tracks third-party components, and produces the evidence economic operators need.
WCAG 2.2 scanning
Automated accessibility scanning of your web properties against WCAG 2.2 Level AA. Color contrast, keyboard navigation, ARIA attributes, and semantic structure — checked continuously.
Third-party component tracking
Your vendor profile in Sudory lists every subprocessor and embedded service. Know which third-party components are in your product — and whether they meet accessibility requirements.
Supply chain visibility
As a distributor, you need to verify your suppliers' accessibility compliance. Sudory's vendor directory shows which vendors have accessibility certifications and WCAG compliance data.
Continuous conformity evidence
The EAA isn't one-time certification. Accessibility must be maintained continuously. Sudory's scanning engine provides ongoing conformity evidence that enters your compliance ledger.
Cross-framework mapping
WCAG findings map to EAA Annex I requirements, but also to BITV 2.0 (Germany), EN 301 549 (EU), and Section 508 (US). One scan, multiple frameworks.
Documentation trail
Economic operators must keep documentation for 5 years. Sudory's compliance ledger is append-only — every scan, every finding, every remediation is timestamped and auditable.
For MSPs
Accessibility as a managed service
Your clients are economic operators — and most don't know it yet. Offer EAA compliance as a service before enforcement begins.
Distributor compliance at scale
As an MSP distributing third-party software, you're an economic operator under the EAA. Sudory helps you verify accessibility across every product you distribute to clients.
Client accessibility audits
Scan your clients' web properties for WCAG 2.2 compliance. Surface accessibility violations before the June 2025 enforcement deadline — and before market surveillance authorities do.
Remediation tracking
Findings enter the compliance ledger. Policies enforce remediation timelines. Role policies ensure the right people are reviewing and approving fixes. The loop closes automatically.
Know your supply chain's accessibility posture
Scan your web properties for WCAG 2.2 compliance. Check your vendors' accessibility data. Build conformity evidence before market surveillance authorities come looking.