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Re: Have I got all of these legal requirements and de facto requirement correct for private sector businesses

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From: Steve Green
Date: Apr 4, 2025 4:31AM

The EU has no jurisdiction outside the EU countries (although it doesn't seem to understand this) so there are limits to what they can do if your website does not conform with the EAA. For instance, they can't force you to attend court, and there is no chance our government would consider an extradition request.

However, they can demand that you cease the provision of your services to the EU. They could even block traffic to your website from EU countries, although I expect they would only do this for very large organisations like Google and Amazon. And in theory, they might be able to arrest you if you set foot in an EU country, although I think this is extremely unlikely. Small and medium size organisations are likely to just go under the radar.

It's worth noting that the EU regards the EAA as applying to EU citizens regardless of where they are in the world. If you provide a service to EU citizens but only outside the EU, then there really is nothing the EU can do to enforce their law.

With regard to VPATs, I wouldn't say they are "a de facto requirement when selling digital products or services to public sector bodies". I have worked for some of these third parties, and I am in a UK government discussion group on accessibility, and VPATs are rarely mentioned. That's not to say they aren't worth doing, especially since they are not particularly difficult or time consuming once you've done a WCAG audit.

Steve Green
Managing Director
Test Partners Ltd