The EAA and B2B Tech: What Vendors Need to Know

The European Accessibility Act (EAA), formally known as Directive (EU) 2019/882, is reshaping the digital landscape across the European Union (EU). Although the law primarily targets consumer-facing businesses, its ripple effects are significant for business-to-business (B2B) vendors—especially those providing software, hardware, and digital services to clients with an EU presence.

Even if your business doesn’t serve consumers directly, your clients’ ability to comply with the EAA may depend on the accessibility of the products and services you supply. And with enforcement beginning in June 2025, both existing contracts and future deals will increasingly hinge on whether your offerings meet EAA requirements.

In this blog, we’ll explore the EAA’s impact on B2B technology vendors, including how the directive will affect vendors’ sales opportunities. We’ll also share best practices for future-proofing your B2B products in the changing EU regulatory landscape.

What the EAA means for B2B vendors

The EAA aims to harmonize accessibility requirements across EU Member States for a variety of consumer products and services, including:

• ATMs, ticketing, and self-service kiosks.
• E-commerce platforms.
• Banking and transportation apps.
• Operating systems, smartphones, e-readers, and more.

While the EAA applies directly to companies that sell these offerings to EU consumers, business-to-consumer (B2C) organizations often rely on third-party vendors for key components—from payment processing software to customer support chatbots. This makes B2B vendors a critical part of the accessibility compliance chain.

Companies that are directly covered by the EAA will need proof that the third-party products they purchase meet accessibility requirements, or they put their own compliance at risk. In practice, that means they’ll increasingly require vendors to provide a completed Voluntary Product Accessibility Template (VPAT) as part of the procurement process.

As a vendor, obtaining a VPAT report that demonstrates that your products are accessible is no longer a “nice to have”—it’s essential for business growth.

The high stakes of selling inaccessible products

As B2C companies covered by the EAA pay closer attention to the compliance of third-party products, accessibility is quickly becoming a necessity for B2B vendors. B2B providers that fail to prioritize accessibility risk lost sales, longer procurement cycles, and exclusion from bids.

This is true for vendors that sell to the public sector, as well as those selling to private businesses impacted by the EAA. That’s because government organizations in the EU are bound by the requirements of the EU Web Accessibility Directive (WAD). Like the EAA, the EU WAD covers many types of third-party content, so public-sector buyers are unlikely to risk integrating inaccessible technology.

And product accessibility issues don’t just create business risks—they can also have legal implications. B2B companies may be held directly accountable for non-compliance in some cases, such as when they’re the economic provider of a product. For instance, if a customer-facing e-commerce website redirects users to a third-party payment platform, this platform is legally required to comply with the EAA.

Accessibility as a competitive differentiator

Accessibility is more than a business obligation for vendors—it’s a competitive advantage. In particular, organizations that build accessibility into their product development process—going beyond table-stakes compliance requirements—differentiate themselves in a crowded technology market. By proactively committing to product accessibility, organizations can:

• Improve overall user experience: Accessible design principles make products easier and more enjoyable for everyone to use, not just people with disabilities. This can help providers gain a valuable edge in a market where products increasingly compete on usability.
• Uphold responsible design practices: A strong accessibility practice sends a powerful signal that your organization prioritizes socially responsible innovation, which may resonate with buyers aiming to demonstrate inclusion and adhere to the EU’s strict environmental, social, and governance (ESG) standards.
• Drive efficiency and innovation: Proactively integrating accessibility into the product development life cycle (PDLC) is faster, and more cost-effective, than reactively fixing issues every time a buyer requests a VPAT report. This frees up development resources for innovation.

Best practices for maximizing product success under the EAA

To meet the growing demand for accessible solutions, B2B vendors should take a structured approach to accessibility. Get started with the following best practices:

Obtain a credible VPAT report.

Engage a reputable expert to obtain a completed VPAT that documents your product’s accessibility status. Producing an accurate, favorable VPAT is a multi-step process that includes:

• Testing: Professionals will test your product for conformance with relevant accessibility standards, including EN 301 549—the harmonized European digital accessibility standard and the presumptive standard for EAA compliance. This testing should include manual evaluation with assistive technologies (AT) used by people with disabilities.
• Remediation: You’ll want to fix any issues that were identified by testers to bring your product into alignment with your buyers’ expectations.
• Validation: After you’ve addressed areas of non-conformance, testers should perform another round of evaluation to ensure that fixes were implemented correctly.
• Delivery: Experts will write a VPAT report demonstrating that your product conforms to accessibility standards.

Importantly, completing a VPAT isn’t a one-time project. You’ll need to refresh your VPAT reports regularly to reflect product updates. VPATs that are over two years old are typically regarded as outdated and unreliable, which may impact sales opportunities. Many organizations have more stringent requirements, requiring VPATs completed within the current year.

Adopt EN 301 549 as a design baseline.

To ensure your product remains accessible over time—streamlining future VPAT updates—make accessibility part of the product development life cycle (PDLC), starting in design. By considering accessibility as early as possible when creating new features and capabilities, you reduce the time developers and QA teams need to spend troubleshooting issues later.

Work with product teams to incorporate accessibility requirements aligned with EN 301 549 into user stories and equip designers with tools and training to apply these standards to new design concepts.

Integrate accessibility into development workflows.

Even when designers prioritize accessibility, issues may surface in development—and it’s faster, and far less risky, to catch and address these issues before code is live. Educate developers about accessibility best practices and provide tools like accessibility software development kits (SDKs) to help teams incorporate accessibility checks into their standard workflows.

Establish strong accessibility governance.

To maintain conformance with EAA requirements—and realize the long-term value of inclusive product design—you’ll need to establish a robust framework for accessibility governance. This framework should include:

• Accountability: Effective governance starts with clear ownership. Assign roles across product, design, development, and compliance teams to oversee accessibility efforts.
• Policies: Establishing internal policies that align with EN 301 549 will help your organization apply accessibility consistently across all phases of the PDLC.
• Training: Ongoing accessibility training for designers, developers, and other key roles empowers teams to work more efficiently and fosters a culture of continuous improvement.
• Ongoing testing: Regular testing—both manual and automated—helps ensure your offerings remain accessible as they evolve, and makes it easier to keep your VPATs up to date.
• User feedback mechanisms: Finally, implementing feedback and escalation mechanisms will ensure that accessibility concerns from users or other stakeholders are addressed quickly and effectively.

Strong governance not only streamlines procurement, but also reinforces your organization’s commitment to responsible innovation.

Accessibility is a strategic imperative for B2B vendors.

The EAA signals a clear shift in how digital products and services are expected to function in Europe. While compliance may initially appear to be the responsibility of B2C companies, the reality is that B2B vendors play a key role.

Digital accessibility is fast becoming a baseline requirement for doing business across the EU. For B2B vendors, getting ahead of this trend is not just about minimizing risk; it’s about future-proofing your products and expanding your potential market.

At Level Access, we’ve spent more than 25 years helping organizations in Europe, North America, and worldwide meet their accessibility goals. Our end-to-end solution spans the three pillars of successful accessibility programs: Audit & Test, Build & Fix, and Governance & Reporting.

Whether you’re obtaining a VPAT report for the first time or optimizing a mature program, our team is ready to help. Contact Level Access today to learn how we can support your journey toward sustainable accessibility and compliance.

Frequently asked questions

1. What is EN 301 549, and why does it matter for B2B vendors?

EN 301 549 is the harmonized European standard for information and communications technology (ICT) accessibility, and the presumptive standard for EAA compliance. It sets out requirements for a wide range of technologies including websites, software, hardware, and telecommunications equipment. Aligning with this standard is essential for B2B vendors with B2C clients that are covered by the EAA. Using EN 301 549 as your design baseline ensures that your product can be integrated into compliant systems without creating risk for your customers.

2. Do B2B vendors need to provide VPATs under the EAA?

While the EAA does not explicitly mandate VPATs for vendors, many B2C organizations will require them as part of their procurement process. A VPAT (Voluntary Product Accessibility Template) is a standardized document that outlines how your product supports accessibility requirements. Providing a VPAT that demonstrates EN 301 549 conformance can make your product more attractive to buyers in the EU and help speed up sales cycles.

3. How can I make my product development process accessibility-friendly?

Start by embedding accessibility checkpoints at each stage of the development lifecycle:

• Define accessibility requirements during planning and design.
• Use automated testing during development.
• Include accessibility reviews in your QA process.
• Consider training your team in accessibility standards and inclusive design principles.
• You’ll reduce the need for costly fixes later, ensure compliance, and create a better product experience for everyone.