European Accessibility Act for SaaS: Does It Apply to You?

Short answer: The European Accessibility Act (EAA) applies to a fixed list of services "provided to consumers after 28 June 2025", and e-commerce services are on that list. If your SaaS sells only to businesses, or you have fewer than 10 staff and no more than EUR 2 million in turnover or balance sheet, you are very likely outside the service rules. If you sell online to EU consumers and are bigger than that, plan for WCAG 2.2 AA and a public accessibility statement.

Every legal quote below comes from the text of Directive (EU) 2019/882 and the regulator pages linked, checked on 10 Nov 2026. The decision flow, checklist and time estimates are ours and are marked that way.

TL;DR#

• It is a list, not a blanket rule. Article 2(2) covers listed services including "consumer banking services", "e-books and dedicated software" and "e-commerce services" (Directive 2019/882).
• Consumers only. The service rules attach to services provided to consumers. A pure B2B tool is usually out.
• Microenterprises are exempt for services. Fewer than 10 persons AND turnover or balance sheet of no more than EUR 2 million.
• In scope? Target WCAG 2.2 AA. W3C says "The 2026 version of EN 301 549 uses WCAG 2.2" (W3C WCAG overview).
• Publish the information. Explain how your service meets the requirements, in your terms or an equivalent document.
• Skip overlays. They do not make a site compliant.

Disclosure: ZeroRaised is a launch site for bootstrapped products and has no commercial relationship with any tool named here. This is general information, not legal advice. If real money or a regulator letter is involved, talk to a lawyer in the country where you sell.

What the European Accessibility Act actually covers#

The EAA is an EU directive, so each member state passes its own law (Ireland's uses S.I. 636/2023). For services, Article 2(2) says the Directive "applies to the following services provided to consumers after 28 June 2025" (Directive 2019/882):

The one that catches most B2C SaaS is (f). Article 3(30) defines e-commerce services as "services provided at a distance, through websites and mobile device-based services by electronic means" and "at the individual request of a consumer with a view to concluding a consumer contract".

Our read: if a consumer can land on your site, pick a plan and pay, that flow looks like an e-commerce service. Signup, pricing, checkout and account pages are the obvious exposure. Ireland's CCPC lists "E-commerce services provided to consumers in the EU", for example "online marketplaces, retail websites" (CCPC: services covered).

Article 3(22) defines a consumer as "any natural person who purchases the relevant product or is a recipient of the relevant service" for purposes outside their trade, business, craft or profession. A company buying seats is not a consumer. A freelancer paying personally might be.

Does the EAA apply to your SaaS? A decision flow#

This flow is ours, built on the definitions quoted above. Work through it in order and stop at the first "out".

1. Do you provide the service to anyone in the EU? No EU customers, no EAA. It follows where the service is provided, not where you are based.
2. Do you sell to consumers, or only to businesses? If your terms, pricing and checkout are genuinely business-only (company name, VAT ID, "for business use" in the terms), you are usually out.
3. Is your service on the list? A consumer SaaS that sells subscriptions online most likely hits (f).
4. Are you a microenterprise? If yes, you are exempt from the service requirements. Keep a short note of why.
5. Still in? Then you need to meet the accessibility requirements, publish information on how you meet them, or document a disproportionate burden assessment for the parts you cannot.

The microenterprise exemption is an AND test#

Article 3(23) defines a microenterprise as "an enterprise which employs fewer than 10 persons" and has "an annual turnover not exceeding EUR 2 million" (or an annual balance sheet total of no more than EUR 2 million). Article 4(5) then says: "Microenterprises providing services shall be exempt from complying with the accessibility requirements" and "any obligations relating to the compliance with those requirements." (Directive 2019/882)

Ireland's regulator says it plainly: "The requirements and obligations of the European Accessibility Act (EAA) do not apply to microenterprises providing services." (CCPC microenterprise guidelines)

Two traps for founders:

• Both parts must be true. Few staff but EUR 2.5 million in turnover and balance sheet fails. A tiny revenue line with 10 or more persons fails too, depending on how your country counts them.
• It is about services. A microenterprise that sells hardware is not covered.

Our read: if you are exempt, file a one-paragraph note with your headcount and turnover for the year. It answers the first question a regulator would ask. You will outgrow the exemption eventually, and accessibility is far cheaper built in than retrofitted.

The disproportionate burden escape hatch#

Article 14(1) says the requirements apply "only to the extent that compliance" does not require a significant change that results in "the fundamental alteration of its basic nature" and "does not result in the imposition of a disproportionate burden on the economic operators concerned".

It is not a free pass. Article 14(2) and (3) say you must "carry out an assessment" against Annex VI, "document the assessment" and "keep all relevant results for a period of five years". Our read: it lets you phase work, not skip the signup form.

What compliance means in practice#

The technical target: WCAG via EN 301 549#

W3C says: "In addressing the European Accessibility Act (EAA), most organizations use WCAG and the European Standard EN 301 549", and "The 2026 version of EN 301 549 uses WCAG 2.2" (W3C WCAG overview). W3C also notes that "WCAG 2.2 does not deprecate or supersede WCAG 2.1", so meeting 2.2 AA covers 2.1 AA too.

Our read: aim for WCAG 2.2 Level AA on every page a consumer touches before and during payment, then work inward.

The paperwork: information on how your service complies#

Article 13(2) says: "Service providers shall prepare the necessary information in accordance with Annex V" and "The information shall be made available to the public in written and oral format". It must be kept "for as long as the service is in operation." Annex V says this information goes in your general terms and conditions or an equivalent document.

The CCPC puts it as: "Prepare the necessary information to explain how the service meets applicable accessibility requirements" (CCPC obligations for businesses).

In practice: an /accessibility page, linked from the footer and referenced in your terms, stating the standard you target, what you tested, known gaps with fix dates, and a contact. Our guide to writing terms of service for a SaaS shows where that reference fits.

If you later find your service does not conform, Article 13(4) says service providers "shall immediately inform the competent national authorities" of the member states where the service is provided.

Who enforces it#

Enforcement is national. Ireland's CCPC runs market surveillance for the EAA and takes complaints. In the Netherlands, ACM says it "enforces the rules on accessibility of e-commerce services and electronic communications services" (ACM accessibility). Penalties are set in each country's law; neither page stated a figure today, so we quote none.

A WCAG checklist for a SaaS signup and checkout flow#

This checklist is ours. It covers landing, pricing, signup, checkout, login and account settings.

1. Keyboard only. Unplug the mouse. Can you reach every field, plan toggle and the pay button with Tab, and activate them with Enter or Space? Custom dropdowns and modals are the usual failures.
2. Visible focus, no traps. You can always see where focus is. Modals, cookie banners and chat widgets let you in and out, and Escape closes them.
3. Colour contrast. Normal text needs "a contrast ratio of at least 4.5:1", large text "at least 3:1", and values are not rounded: "4.499:1 would not meet the 4.5:1 threshold" (W3C, SC 1.4.3). Check grey placeholders and disabled buttons.
4. Real labels. Every input has a programmatic label, not just placeholder text.
5. Useful errors. Errors say what went wrong and how to fix it, in text next to the field, announced to screen readers. Colour alone is not enough.
6. CAPTCHA alternatives. Offer a non-visual path, or swap to an invisible or proof-of-work check.
7. Cookie banner. Keyboard-dismissable and screen-reader readable. Our GDPR checklist for solo SaaS founders covers what it has to say.
8. Third-party checkout. Test the embedded payment form too. It is part of the path to the contract.
9. Zoom and reflow. At 200% zoom and on a narrow phone, signup works without horizontal scrolling.
10. Icons, language, timeouts. Icon-only buttons have accessible names, pages declare their language, and session timeouts warn users and let them extend.
11. Invoices and PDFs. Receipts come as accessible HTML or tagged PDFs, not scanned images.

Free tools to test with#

Our read: automated tools catch mechanical problems (labels, contrast, empty buttons) but not whether a screen reader user can finish checkout. Do one keyboard-only run and one NVDA or VoiceOver run of signup and payment, then add Pa11y or an axe check to CI so regressions fail the build.

Why overlay widgets are not the answer#

Overlays (a script that adds a toolbar and promises instant compliance) are tempting. Do not rely on one. The Overlay Fact Sheet concludes: "No overlay product on the market can cause a website to become fully compliant with any existing accessibility standard and therefore cannot eliminate legal risk."

On 22 April 2025 the US FTC "approved a final consent order against accessiBe". It alleged "accessWidget did not make all user websites WCAG-compliant and these claims were false, misleading, or unsubstantiated", and the order "requires the company to pay $1 million" (FTC; summary from the National Law Review; background from TechCrunch, 3 Jan 2025).

What it costs a solo founder#

Our estimates for a small SaaS with a marketing site, pricing page and hosted checkout, not market data:

Our read: roughly a working week if your front end is in decent shape. Fold it into your product launch checklist rather than treating it as a separate project.

Frequently asked questions#

Does the European Accessibility Act apply to B2B SaaS?#

Usually not as a service. The EAA's service obligations apply to listed services provided to consumers, and a consumer is a natural person acting outside their trade, business, craft or profession. If you only sell to businesses and your terms say so, you are generally outside the service list. Check this with a lawyer if some of your customers are sole traders or hobbyists signing up personally.

Is my small SaaS exempt as a microenterprise?#

Probably, if you have fewer than 10 persons and an annual turnover or balance sheet total of no more than EUR 2 million. Both parts must be true. Article 4(5) says microenterprises providing services are exempt from the service accessibility requirements and related obligations. The exemption does not cover microenterprises that place products on the market.

Which WCAG level does the EAA require?#

The Directive itself does not name WCAG. W3C says most organisations addressing the EAA use WCAG and the European Standard EN 301 549, and that the 2026 version of EN 301 549 uses WCAG 2.2. Our read: aim for WCAG 2.2 Level AA, which also satisfies WCAG 2.1 AA.

Do I need an accessibility statement?#

If you are in scope, yes in substance. Article 13 says service providers must prepare information in line with Annex V and make it available to the public in written and oral format. Annex V points to your terms and conditions or an equivalent document. Ireland's CCPC says that information must explain how the service meets the accessibility requirements.

Will an accessibility overlay widget make my SaaS compliant?#

No. The Overlay Fact Sheet says no overlay can make a website fully compliant with any existing accessibility standard. In April 2025 the US FTC approved a final order requiring accessiBe to pay $1 million after alleging its claims that its widget made sites WCAG-compliant were false, misleading or unsubstantiated.

Launch something everyone can use#

ZeroRaised is a launch directory for products built without institutional VC. Once your signup flow works with a keyboard and a screen reader, submit your product for free. For more practical guides on legal, pricing and growth without investors, join the ZeroRaised newsletter.

Sources#

• Directive (EU) 2019/882, text (legislation.gov.uk copy), last checked 10 Nov 2026 (official text: EUR-Lex)
• CCPC: European Accessibility Act in Ireland, last checked 10 Nov 2026
• CCPC: EAA guidelines for microenterprises, last checked 10 Nov 2026
• CCPC: obligations for businesses, last checked 10 Nov 2026
• CCPC: products and services covered, last checked 10 Nov 2026
• ACM: accessibility, last checked 10 Nov 2026
• W3C: WCAG overview, last checked 10 Nov 2026
• W3C: Understanding SC 1.4.3 Contrast (Minimum), last checked 10 Nov 2026
• Deque: axe DevTools browser extensions, last checked 10 Nov 2026
• WebAIM: WAVE extension, last checked 10 Nov 2026
• Chrome for Developers: Lighthouse overview, last checked 10 Nov 2026
• NV Access: NVDA, last checked 10 Nov 2026
• Apple: VoiceOver User Guide for Mac, last checked 10 Nov 2026
• Pa11y on GitHub, last checked 10 Nov 2026
• Overlay Fact Sheet, last checked 10 Nov 2026
• FTC: final order requiring accessiBe to pay $1 million, last checked 10 Nov 2026
• TechCrunch: FTC orders accessiBe to pay $1M, last checked 10 Nov 2026