SCOPE FIRST · FICTIONAL SAMPLE

Northmere Outfitters — an invented business, not a customer

Fictional Scope Report — Northmere Outfitters

£195 service example · 1 October 2026 · conditional applicability and next actions

1. Decision and immediate next steps

Under the scenario below, Northmere should treat its German consumer shopping service as requiring an accessibility workstream. The assumed post-June-2025 service and business size give no basis for the service-provider microenterprise exemption. Confirm the contracting entity, market and exemption evidence before relying on this conclusion. For the Great Britain service, assess reasonable adjustments separately rather than treating the EU analysis as the answer.

  1. Name the legal seller and confirm that German consumers can actually contract through the production journey. Keep the terms, countries served and a safe demonstration of the journey as evidence; a country option alone is insufficient.
  2. Confirm the relevant business size and whether linked or partner enterprises affect the calculation. Record the source and period of each figure, rather than estimating from social media or a team page.
  3. Agree a bounded technical review of product selection, basket changes, address entry, errors, review and payment, including third-party components. Assign an owner for remediation and retesting.
  4. Review the German service-information requirements and the Great Britain adjustment process. Publish only statements supported by the review, with an accessible route for reporting difficulties.

2. Scope, evidence and assumptions

The named website is a locally authored demonstration containing home, about, collection, product, cart and checkout templates. It ends at a local review screen and cannot take payment or place an order. The £195 Scope Report would ordinarily cover one named public website or checkout using its URL, countries served, customer type and the decision the report needs to support. This sample substitutes expressly invented facts to demonstrate the reasoning; it does not verify a real business.

Scenario facts: all commercial facts are invented
QuestionScenario assumptionEvidence needed for a real report
OperatorUK-based Northmere Outfitters contracts directly with the consumer.Legal seller, terms, group structure and any marketplace/payment-provider allocation.
Service and customersOnline clothing sales to consumers in Great Britain and Germany.Countries actually served; B2C/B2B split; product and checkout routes.
TimingThe consumer e-commerce service continues during 2026, after 28 June 2025.Service start/change dates and any relied-on legacy contracts or equipment.
Size16 persons employed; €3.2 million annual turnover; €2.6 million annual balance-sheet total.Relevant accounting period, persons employed and applicable enterprise calculation.
ExceptionsNo supported microenterprise, transition, fundamental-alteration or disproportionate-burden claim supplied.A documented assessment and the precise provision for any proposed exception.
Verified local boundaryThe fixture has six representative templates and local-only form logic.This is evidence from the fixture source, not proof of real sales, EU availability or legal compliance.

Unknown in a real commission until supplied: exact entity, actual countries accepted, turnover and balance sheet, employment calculation, connected enterprises, legacy arrangements, platform contracts, accessible support, payment provider behaviour and the production site’s technical barriers. The demonstration does not fill these gaps with estimates.

3. Jurisdiction and service analysis

Germany: consumer e-commerce is the relevant service

The EAA covers specified consumer services, including e-commerce; implementation is through national law. Germany’s BFSG includes consumer e-commerce services provided after 28 June 2025. In this scenario the online service, rather than the ordinary jacket as a listed EAA product, is the relevant category. This is a conditional classification, not a determination about a UK retailer merely because its site is viewable abroad. EAA: Articles 2 and 3; BFSG: §§1–2.

German rules address the service journey, not only its landing page. BFSGV §19 specifically addresses identification, authentication, security and payment functions provided within e-commerce services, and accessibility information where supplied by the responsible economic operator. Therefore the scoping conversation must include checkout suppliers and support, even though this local fixture contains no payment integration. BFSGV §19.

Microenterprise: do not substitute an SME label

The service exemption concerns microenterprises: fewer than 10 persons employed and annual turnover not exceeding €2 million or annual balance-sheet total not exceeding €2 million. The invented 16-person figure fails the employment limb, so the scenario does not qualify. The supplied financial figures also exceed the two thresholds. A real assessment needs the proper enterprise calculation; a marketing description such as “small” is not evidence. BFSG: §2(17), §3(3).

Timing and other exceptions

A website predating June 2025 does not by itself establish an exemption. Transitional arrangements concern specified existing service contracts and products used to provide services. No such evidence is assumed here. Fundamental alteration and disproportionate burden require assessment of the particular requirements; outsourcing is not itself a blanket exemption. Obtain specialist advice before relying on an exception. EAA: Articles 14 and 32; BFSG: §§16–17, 38.

Great Britain: a separate service-provider duty

The Equality Act service-provider framework in Great Britain requires reasonable changes where disabled customers would otherwise face substantial disadvantage. Government guidance says providers should think ahead about barriers and should not charge disabled customers for reasonable adjustments. What is reasonable depends on the circumstances. An EU service exemption would not settle this separate question. This report does not assess Northern Ireland or equate a WCAG result with a legal determination. Government service-provider guidance.

4. Practical risk and review boundary

The practical priority is whether a customer can select a product, correct mistakes and progress through checkout independently. This Scope Report does not enumerate WCAG failures or claim keyboard, screen-reader or payment testing. The separately labelled fictional Full Audit demonstrates technical findings based on recorded browser checks of the same fixture. Its results concern this deliberately authored local example, not any production retailer.

WCAG 2.2 Level A and AA is a useful explicit technical review target. It is not a substitute for identifying the applicable service obligations, information requirements, national rules or reasonable adjustments. A tool reporting no violations does not establish legal compliance or complete technical conformance. WCAG 2.2.

Review the whole service at agreed boundaries
AreaQuestion to resolveEvidence or deliverable
Product selection and basketCan customers understand options and operate selection and quantity controls?Agreed templates and states, browser checks, reproducible issue records.
Input and recoveryAre fields identifiable, errors explained and earlier input preserved?Empty, invalid and corrected states; associated labels and messages.
Payment and suppliersWhich parts are controlled by the seller, platform and payment provider?Component inventory and safe test access agreed without handling passwords or real payments.
Help and service informationCan a customer obtain help and understand accessibility information?Accessible support route; accurate service information reviewed against relevant requirements.
MaintenanceWho fixes, retests and owns changes after release?Named owner, release/retest evidence and an issue process.

5. Prioritised action plan

Suggested sequence; no work or expenditure is implied
Priority / owner roleActionDone proof
First — business ownerConfirm entity, markets, consumer contracts, size and any exception evidence.Completed intake with attributable source documents and unresolved questions recorded.
Next — product / developerAgree representative templates, components, states and browsers for technical testing.Written scope and safe access route; clear exclusions and delivery date before payment.
Then — developerAddress demonstrated barriers in the purchase journey before cosmetic improvements.Reproduction succeeds before the change and the same check succeeds after it; regression evidence retained.
In parallel — service ownerPrepare accessible help and truthful service information; obtain legal advice on contested scope or exceptions.Reviewed information, tested contact route and documented legal questions where necessary.
Ongoing — release ownerRetest changed components and reassess new markets or business-size changes.Release checklist and updated evidence; no unsupported blanket statement.

These are dependencies, not fixed engineering estimates. Remediation duration cannot be derived from a scoping report without the actual platform, issue set and developer access. No fines, avoided claims, conversion uplift or revenue are predicted.

6. Intake questions for the real engagement

  1. What is the exact URL and legal entity that contracts with customers? Is the site operated for another seller or through a marketplace?
  2. Which countries can consumers actually order from, and are any journeys exclusively business to business?
  3. What are the relevant employment, turnover and balance-sheet figures, period and connected-enterprise facts?
  4. When was the service provided or changed, and what precise transitional arrangement or exception is being relied on?
  5. Which storefront, checkout, payment, identity and support components are third party? Who can change each?
  6. What customer difficulties, technical test results or accessibility information already exist?
  7. Which named templates, error states, languages, devices and assistive technologies need technical review?
  8. Who will approve the scope, provide safe test access, implement fixes and retain retest evidence?

7. Deliverable and exclusions

The £195 Scope Report supplies a sourced applicability assessment for one named public website or checkout, assumptions, exclusions, practical risk and prioritised next actions. The published delivery promise is three working days after complete inputs: URL, countries served, customer type and the decision the report needs to support, with further facts requested where the conclusion depends on them. This sample is already complete as a fictional explanation; no purchase or delivery clock is represented.

The £595 Full Audit is separate technical work on agreed pages, templates, journeys and viewports, reporting confirmed WCAG 2.2 Level A/AA findings with reproduction and remediation guidance. Its exact scope, access and delivery date are agreed before payment; this sample does not extend the three-working-day Scope Report promise to the Full Audit. Screen-reader sessions or additional evaluation must be expressly agreed and actually performed before being claimed.

Excluded here: binding legal advice, litigation or penalty prediction, all-country legal coverage, certification, production conformance, remediation implementation, private account or payment access, personal data, real orders, and testing every URL or variant. Legal or exemption disputes should go to an appropriate adviser. If inputs contradict the scenario, revise the conclusion rather than reusing it.

8. Source register and freshness

Sources accessed on 1 October 2026. Legal text is primary; the English descriptions of German provisions are report paraphrases. The consolidated BFSG text was retrieved successfully; individual section pages intermittently timed out. EUR-Lex’s English indexed text was available, while a later direct request displayed a robot-check page; no restriction was bypassed. The Great Britain guide is older government guidance, whose page states that its original content was not substantively updated when converted to HTML. This is not a claim that every national interpretation has been reviewed.

Primary sources supporting this bounded assessment
SourceRelevant materialUse and limits
L01 — EAADirective (EU) 2019/882, Articles 2–4, 14, 32.Specified consumer services, national implementation, exemptions and transitions; not a complete national-law analysis.
L02 — GermanyConsolidated BFSG, §§1–3, 14, 16–17, 38 and Annex 3.Scope, microenterprise, service duties and exceptions. Current consolidated text retrieved.
L03 — GermanyBFSGV §19.E-commerce information and identification/authentication/security/payment functions; official indexed text retrieved.
L04 — Great BritainGovernment disability guide for service providers.Reasonable adjustments and thinking ahead; government guide content dates from 2010, page updated 2013, HTML conversion 2022.
T01 — Technical referenceWCAG 2.2 Recommendation.Technical review target; no full conformance or legal-equivalence claim in this Scope Report.