guide
EAA for saas & software: requirements, priorities, and audit checklist
EAA compliance for SaaS products requires applying European Accessibility 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 EAA apply to SaaS products?
The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.
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 EAA 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 EAA on a SaaS & Software site
1. Confirm in-scope status: Determine whether your product/service falls under EAA scope and whether you sell into the EU. Confirm whether micro-enterprise exemption applies.
2. Map requirements to EN 301 549: The harmonised standard EN 301 549 incorporates WCAG 2.1 AA for web/mobile and adds requirements for hardware, software, documentation, and support.
3. Audit and remediate: Run combined automated + manual audit. Remediate at source. Prioritise authentication, payment, search and core transaction flows.
4. Publish an EAA accessibility statement: Per Article 13. Disclose conformance, exceptions claimed (disproportionate burden, fundamental alteration), and contact for complaints. Sample templates available from national bodies.
5. Maintain market surveillance readiness: Keep technical documentation, conformity assessments, and ACR/VPAT current. Be prepared for member-state authority requests.
Sources
- Directive (EU) 2019/882 (European Accessibility Act) — European Union
- EN 301 549 v3.2.1 — ETSI
- Section508.gov VPAT — GSA
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Does EAA apply to saas & software websites?
The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.
What are the most common EAA 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.
Stop guessing. Get the audit a Fortune 500 a11y team would have written.
Free audit on your live URL. No sign-up. IAAP-format report. Ready in hours.
founders@accessivepath.com · +977 9851094056