guide
ACA for saas & software: requirements, priorities, and audit checklist
ACA compliance for SaaS products requires applying Accessible Canada Act to the specific failure points typical of the saas & software industry — including component libraries without semantic markup, modal dialogs that trap focus incorrectly, data tables without programmatic structure.
Does ACA apply to SaaS products?
The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.
SaaS & Software accessibility — the lay of the land
SaaS vendors face accessibility through two channels: their own marketing site (subject to ADA Title III), and their product (subject to procurement-driven VPAT requirements and EAA scope for consumer services). Enterprise procurement increasingly requires a current VPAT.
Where ACA bites hardest in SaaS products
• Component libraries without semantic markup
• Modal dialogs that trap focus incorrectly
• Data tables without programmatic structure
• Drag-and-drop without keyboard alternatives
• Status messages not announced to AT (4.1.3)
Remediation priorities
• Core admin / dashboard navigation
• Forms, validation, and error recovery
• Tables, charts, and data export
• Component library (button, input, modal, menu primitives)
• Embedded customer-facing widgets
How to comply with ACA on a SaaS & Software site
1. Publish an accessibility plan: Every federally regulated entity must publish a multi-year accessibility plan, updated every three years.
2. Establish a feedback mechanism: Accept and respond to accessibility complaints.
3. File progress reports: Annual progress report between plans.
4. Meet technical ICT requirements: Reference EN 301 549 for digital products and services.
Sources
- Accessible Canada Act — Government of Canada
- Section508.gov VPAT — GSA
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Does ACA apply to saas & software websites?
The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.
What are the most common ACA failures in SaaS products?
Component libraries without semantic markup Modal dialogs that trap focus incorrectly Data tables without programmatic structure
What conformance level should a saas & software site target?
WCAG 2.2 Level AA is the consensus target for legal compliance and the level referenced by virtually every national accessibility law.
Do SaaS vendors need a VPAT?
Increasingly yes. Enterprise procurement teams — particularly in higher education, healthcare, government, and large finance — require a current VPAT/ACR before purchase. Federal vendors require Section 508 VPATs explicitly.
Is the SaaS marketing site or the product more important for accessibility?
Both are in scope under different regimes. The marketing site is ADA Title III (public accommodation). The product is procurement-VPAT-driven and increasingly EAA-driven for consumer offerings. A vendor should not treat one as adequate cover for the other.
What is the most cost-effective way for a SaaS team to start?
Three steps: (1) accessibility-instrumented component library so new screens inherit conformance; (2) axe-core in CI for regression; (3) annual manual audit against WCAG 2.2 AA with an IAAP-certified team.
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