EAA Compliance for Web Agencies: A Client Portfolio Playbook
The European Accessibility Act applies to the websites you build for clients, not only to your own site. For an agency, that is both a liability and a recurring-revenue opportunity. This playbook explains how to handle EAA compliance across an entire client portfolio, from inventory to ongoing monitoring.
Why the EAA is now an agency issue
Since June 28, 2025 the EAA has been enforceable across the EU, and enforcement has accelerated into 2026. Authorities assess websites against WCAG 2.1 Level AA, via the harmonized European standard EN 301 549. For an agency, every client site that serves EU users is potentially in scope. Two things follow. First, a non-compliant client site is a reputational and contractual risk for the agency that built it. Second, and more positive, compliance is a service clients now need and will pay for on an ongoing basis.
Step 1 — Inventory which client sites are in scope
Start by listing every client site and flagging those that serve EU residents and fall in obligated sectors: e-commerce, banking and payments, travel and ticketing, telecommunications, e-books and streaming. The location of the client company does not matter; what matters is whether EU users are served. This inventory becomes your prioritization map and the basis for scoping the work.
Step 2 — Run a baseline audit per site
For each in-scope site, run an automated WCAG audit to get a baseline. A scan that runs the major WCAG 2.1/2.2 checks surfaces the high-frequency failures fast: missing alt text, low color contrast, keyboard traps, unlabeled form fields, and a missing accessibility statement. FixMyWeb runs 201 automated checks per page in about 60 seconds and returns issues mapped to the exact WCAG criterion with a fix snippet. For a portfolio, the bulk scan handles many URLs at once.
Step 3 — Prioritize remediation by risk
Fix critical and serious issues first, because they carry the highest legal exposure and block real users: keyboard operability, form labels, and contrast on primary actions. Automated scans catch a large share of issues; pair them with manual checks for the rest, such as screen-reader flows and focus order. Resolve the issues that appear across many client sites first, since one shared component fix can clear the same failure everywhere.
Step 4 — Publish an accessibility statement for each client
The EAA requires covered services to publish an accessibility statement, and its absence is one of the easiest violations for an inspector to verify without technical expertise. Publishing a statement, even while remediation is ongoing, demonstrates good faith to regulators. A statement generator turns this into a quick, repeatable task per client.
Step 5 — Set up monitoring so fixes stay fixed
Accessibility regressions arrive with every deployment. A one-time audit is a snapshot, not compliance. Schedule recurring scans on each client's critical pages so new issues are caught before they become complaints. Continuous monitoring is also what lets you offer compliance as an ongoing service rather than a one-off project.
Step 6 — Productize EAA compliance as a service
This is where the opportunity sits. Package the work above into a recurring offer: an initial audit, a remediation sprint, an accessibility statement, and ongoing monitoring with a monthly report. White-label reports let you deliver findings under your own brand, and a VPAT/ACR gives enterprise clients the documentation their procurement teams ask for. One agency relationship can cover dozens of client sites, which is why accessibility is becoming a standard line item in agency retainers.
How FixMyWeb fits an agency workflow
FixMyWeb was built for this: instant URL scans with fix snippets, bulk multi-URL scanning for portfolios, white-label client reports, a VPAT/ACR generator, an accessibility statement generator, and monitoring. There is a free scan with no signup, so you can audit a client site before you even pitch the work. If you are weighing tools, see how FixMyWeb compares to axe and to accessiBe.
Start with one client site
Pick your highest-traffic client and run a free scan now. In about 60 seconds you will see where they stand against WCAG and the EAA, and you will have a concrete starting point for the conversation.