Agency liability playbook, Part 2: The EAA manufacturer vs service-provider trap

Under EU accessibility law, role classification matters. Depending on service design and market position, an agency may assume responsibilities that resemble an economic-operator role in specific engagements.

Where Agencies Misclassify Risk

The common mistake is assuming "we are only a vendor" without reviewing actual operational role:

  • who controls product decisions
  • who places the service on the market
  • who issues conformance-facing representations

When those functions are agency-controlled, exposure can increase materially and should be assessed per jurisdictional transposition.

Practical Governance For EU-facing Work

  • define legal role assumptions in contract exhibits
  • map responsibilities for statements, testing, and remediation
  • track cross-border deployment and authority contacts
  • align controls with ongoing conformance obligations

Claim-level Citation Notes