guide
EAA for SaaS products in Spain — compliance checklist
Operating a saas & software business in Spain after 28 June 2025 means complying with the country's national EAA transposition (Real Decreto 193/2023) layered on top of EN 301 549 — and addressing saas & software-specific failure modes including component libraries without semantic markup and modal dialogs that trap focus incorrectly.
EAA in Spain
Transposition: Real Decreto 193/2023. Surveillance: AGE / Ministerio de Derechos Sociales. Max penalty: €1,000,000.
SaaS & Software accessibility — what is in scope
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.
Common failures 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)
EAA compliance checklist
1. Confirm in-scope status. 2. Map to EN 301 549. 3. Audit and remediate. 4. Publish a localised accessibility statement (Article 13). 5. Maintain technical documentation for market surveillance.
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Does the EAA apply to non-EU SaaS products selling into Spain?
Yes. The EAA applies to any product or service placed on the EU market or offered to EU consumers, regardless of vendor headquarters.
What is the maximum penalty in Spain?
€1,000,000
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.
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