Compliance

EAA Audit Template: What EU Web Agencies Actually Bill Clients For (2026)

Aug 2026 · 8 min read

The European Accessibility Act's compliance deadline passed on 28 June 2025. 2026 is the first full year of enforcement, and the scope is wide: e-commerce is explicitly covered, including non-EU companies selling into the EU, and only microenterprises — under 10 employees, €2M or less in turnover — are exempt. Reported fines run past €100,000 per country. If your agency sells web services in the EU, clients are going to start asking about this, if they haven't already.

The problem isn't finding accessibility issues on a site. Free tools do that well. The problem is what you hand the client afterward.

Why a raw scan isn't a deliverable

Run axe DevTools or WAVE against any real website and you'll get a list of findings in developer language — "aria-hidden element must not be focusable," "elements must have sufficient color contrast." That's the right output for a developer fixing code. It's the wrong output for a client meeting, and it's the wrong output for a regulator asking for evidence of due diligence.

axe Pro (roughly $40–45/user/month) stays developer-oriented for the same reason — it's built for the person fixing the issue, not the person who has to prove the issue was checked for. Enterprise platforms like Silktide solve the reporting problem, but at enterprise pricing: thousands of dollars a year, aimed at large in-house teams, not a two-to-fifty-person agency billing per project.

That gap — evidence-grade output at agency prices — is what a proper audit template needs to close.

What a real EAA audit template actually contains

1. Automated scan, as the starting point

An in-page axe-core scan catches the mechanically detectable issues: missing alt text, insufficient contrast ratios, malformed ARIA attributes, missing form labels. This is necessary but not sufficient — most real accessibility failures aren't things a script can see.

2. Guided manual checks for what automation misses

Keyboard traps, illogical focus order, screen-reader announcement quality — these need a human actually tabbing through the page and listening to what a screen reader says. A template should walk the auditor through this systematically, with annotated screenshots as evidence for each check, not leave it to memory.

3. Severity and clause mapping

Every finding needs two things attached to it: a severity level (so the client knows what to fix first) and the specific WCAG 2.2 success criterion and EN 301 549 clause it violates (so the report reads as regulatory documentation, not opinion). "This fails 1.4.3 Contrast (Minimum)" is defensible. "This looks hard to read" is not.

4. White-label output

The report needs to leave under the agency's own brand, not the tool vendor's. A PDF or a shareable link with your agency's logo on it is what makes the audit feel like your deliverable, worth your invoice — not a third-party tool's output you're forwarding.

5. A monitoring layer

A site that passes today can fail next month — a new plugin, a redesigned header, an intern's CSS change. Scheduled re-crawls that flag regressions turn a one-time audit fee into an ongoing reason to stay engaged with the client. This is the single highest-leverage addition to the template: it's the difference between one invoice and a retainer.

Cost comparison

Tool Price Client-ready output Clause mapping Monitoring
axe DevTools / WAVE Free
axe Pro ~$40–45/user/mo
Silktide Thousands/yr
AccessProof €59/auditor/mo ✓ 10 sites/seat

Frequently asked questions

What is an EAA audit template?

A structured format for documenting a website's accessibility conformance against WCAG 2.2 and EN 301 549 — the standard EU regulators reference under the European Accessibility Act. It maps each finding to a specific clause, a severity level, and evidence, so the document reads as regulatory evidence rather than a raw scan log.

Is the European Accessibility Act actually enforced yet?

Yes. The compliance deadline passed on 28 June 2025, and 2026 is the first full year of enforcement. Scope is broad — e-commerce is explicitly covered, including non-EU merchants selling into the EU — and only microenterprises (under 10 employees, €2M or less turnover) are exempt. Reported per-country fines run past €100,000.

What's the difference between a free accessibility checker and an EAA audit report?

Free checkers output console-style findings aimed at a developer — useful for fixing code, not for showing a client or a regulator. An EAA audit report translates the same findings into clause-mapped, severity-scored, branded documentation a non-technical reader can act on.

How do agencies turn a one-off accessibility audit into recurring revenue?

By pairing the initial audit with scheduled re-scans. A site that passes today can regress with the next content update; monitoring catches that automatically and gives the agency a reason to check back in every month instead of closing the ticket after one report.

See what a clause-mapped report actually looks like

AccessProof runs the scan, the guided manual checks, and the clause mapping, then generates the white-label report — plus scheduled monitoring across 10 sites per seat. €59/auditor/month.

See AccessProof
Evgeny Goncharov - Founder of TechConcepts

Evgeny Goncharov

Founder, TechConcepts

I build small B2B tools and automation systems. Previously at a large search platform and Big 4 advisory. Madrid.

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