EAA for web agencies: what you owe your clients and how to document the work

Since the European Accessibility Act (EAA) started to apply on 28 June 2025, agencies get the same question from retail and service clients: "Is our site compliant?" The honest answer is rarely a plain yes or no. This guide is about how to answer well, protect your agency and give clients something they can show a regulator or a customer. It is practical guidance, not legal advice.

Whose obligation is it?

In general, the EAA's obligations for services such as e-commerce fall on the provider of the service, that is your client who sells to consumers, not on the agency that built the site. That does not make it your client's problem alone. Your contract decides what you promised, and clients increasingly expect accessibility to be part of a professional delivery. Some clients, such as micro-enterprises under the directive's exemption for services, may not be covered at all. Ask a lawyer about each client's position.

What a scan can and cannot tell you

Automated scanning is essential, because it finds the same mistakes again and again and catches regressions. But it only covers part of the picture. Deque, the company behind axe-core, reported in 2022 that its automated testing finds 57.38% of issues by volume in its own audit data (a vendor figure, not an independent study). Other criteria, such as whether alternative text is meaningful or whether a checkout works with a screen reader, need a person. A clean scan therefore means "no automatically detectable issues found on the pages tested on this date", never "compliant".

What to put in the contract

• The standard and the version. For example WCAG 2.1 Level AA as referenced by EN 301 549 v3.2.1, and note that a newer EN 301 549 based on WCAG 2.2 is expected to become the reference (details).
• The scope. Which templates and journeys are included (home, product, cart, checkout, account), and what is excluded, such as third-party widgets and payment pages you do not control.
• The method. Automated scans, manual checks and assistive-technology testing, and how often.
• Who owns new content. Editors add images, PDFs and videos after launch. Say who is responsible for alternative text and captions.
• Remediation. How findings are prioritised and how quickly critical ones are fixed.
• Ongoing monitoring. Accessibility regresses when code and content change, so a one-time audit expires. Offer monitoring as a recurring service.

The evidence package

If a customer, a procurement team or a supervisory authority asks, your client should be able to show the work, not just claim it:

1. A dated scan history showing issues found, fixed and recurring.
2. An issue log with status, owner and a reason for anything dismissed.
3. Manual test notes: what was checked by hand, by whom and when.
4. An accessibility statement on the site that describes known limitations and a contact route, and that matches reality.
5. A change log showing that accessibility is checked when the site changes.

Turning it into a service

Agencies that package this as a monthly retainer (monitoring, a short report, a fix budget) avoid arguing about scope later and give clients something predictable. See the agency guide for how to price and sell it.

WCAGAlert is built for exactly this workflow: scan every client site on a schedule, keep the history, add guided manual checks and send white-label reports. See WCAGAlert for agencies or run a free check on a client site to start the conversation.