By Mehdi HassanWhat is the European Accessibility Act?
The European Accessibility Act (EAA) is an EU directive that sets common accessibility requirements for a list of products and services sold in the EU. It was adopted in 2019 as Directive (EU) 2019/882, each member state wrote it into national law, and those laws have applied since 28 June 2025. Enforcement is run nationally by market surveillance authorities, which set their own penalties.
For websites and apps, the EAA's practical effect is simple: if your service is covered, its website and app must be accessible, and you must explain how. The technical benchmark is the harmonised standard EN 301 549, whose web requirements map to WCAG Level AA. This article covers the EU side; our hub on website accessibility compliance puts it alongside US law.
Does the European Accessibility Act apply to SaaS companies outside the EU?
Yes, the European Accessibility Act can apply to SaaS companies outside the EU, because it covers services offered to consumers in the EU regardless of where the provider is based. A US or UK startup with EU consumer customers is treated like an EU one for those services. The question isn't where you are, but who you sell to and what you sell.
Run three tests. First, do individual consumers in the EU use or buy from you, or only businesses? Second, is what you offer on the EAA's list of services? Third, are you small enough to be a microenterprise? If the answers are consumers, yes and no, you're very likely in scope.
Your situation | Likely EAA position | What to do |
|---|---|---|
B2B SaaS sold only to companies, invoiced | Often outside the listed services | Still target WCAG AA for enterprise buyers |
SaaS with self-serve consumer plans and online checkout | Signup and checkout likely an e-commerce service | Make the full purchase flow accessible |
Consumer app sold by subscription in the EU | Likely in scope as an e-commerce service | Website, app and statement all in scope |
Fintech offering consumer banking services | In scope as a listed service | Treat as a priority; get legal review |
Marketing site only, sales via demo calls | Usually lower exposure | Fix basics; publish a statement anyway |
Very small team under the microenterprise limits | Exempt from the service requirements | Document the exemption; fix basics anyway |
If your situation is mixed, like a mostly B2B product with a self-serve tier individuals can buy, treat the consumer-facing flows as in scope. It's the cautious reading, and it costs little extra if you're building those flows well anyway.
Which services does the EAA cover?
The EAA covers a defined list of services, not every website. The ones most relevant to startups are e-commerce services, consumer banking services, e-books and e-reading software, electronic communications, and websites and apps for some passenger transport services. Audiovisual media services have requirements for how people access them.
E-commerce is the broad one. The directive treats it as services provided at a distance, through websites and apps, at a consumer's request, with a view to concluding a consumer contract. That reaches beyond online shops: a consumer subscription flow, an online booking that ends in payment, or a marketplace checkout can all fall under it. What generally isn't covered is a business tool bought through a sales process by companies.
What about products, not services?
The EAA also covers products such as computers and operating systems, smartphones, self-service terminals like ticket machines and ATMs, e-readers and some consumer equipment for communications and media.
If you only make software sold as a service, the product rules usually don't apply to you. If you make hardware, or software that ships as part of a covered product, the product rules and their conformity steps are a separate question to take to a lawyer.
What is the EAA microenterprise exemption?
The EAA microenterprise exemption means very small companies that provide services don't have to meet the directive's service accessibility requirements. The directive defines a microenterprise by headcount and annual turnover or balance sheet total; check the current thresholds in the directive text against your own numbers before relying on it. Microenterprises making products are not exempt in the same way.
Two cautions. The exemption is a reason you won't be fined, not a reason your site is usable, and enterprise buyers, investors and US plaintiffs don't care about it. And startups grow out of it quickly: once you hire past the limit, the requirements apply to services you offer from then on. Building accessibly while you're small avoids a rushed fix later.
What does EN 301 549 require for websites?
EN 301 549 is the European standard that turns the EAA's general requirements into testable criteria, and for web content it points to WCAG Level AA. Its current published version aligns with WCAG 2.1 AA. Targeting WCAG 2.2 AA covers that and the newer criteria, so it's the safer goal for anything you're building now.
In practice, EAA compliance for a website means the same work as WCAG AA anywhere: contrast, keyboard access, labels, captions, focus, structure and working with screen readers. Our WCAG 2.2 checklist splits those items by copy, design and development. The EAA adds an information duty on top: you must explain how your service meets the requirements, in your terms or a public statement.
That statement is where many teams stall. Our accessibility statement template is written to cover EAA expectations, including how to report known issues honestly. Most companies link it from the footer; our guide to what belongs in a SaaS website footer shows where it usually sits.
How does the 2030 transition period work?
The 2030 transition gives some existing services more time, but it doesn't delay the EAA for new ones. Broadly, service providers can keep using products they lawfully used before 28 June 2025 to deliver similar services until 2030, and some service contracts agreed before that date can run on unchanged until they expire, within a time limit the directive sets.
For a startup, the transition rarely helps much. New websites, new apps, new signup flows and new contracts are covered now. And if you redesign your site or ship a new version of your app, treating it as 'the same old service' under the transition is a weak position. The honest reading: plan as if the rules apply to everything you launch from mid-2025 on.
What should a non-EU SaaS company do about the EAA?
A non-EU SaaS company should decide whether it's in scope, then fix its consumer-facing flows to WCAG AA and publish a statement. The work is the same as US ADA risk reduction, so one program covers both. Here's the order we suggest.
Map who buys and how
List every route by which EU individuals can sign up, pay or use your service: self-serve plans, app stores, marketplaces. Those are your likely in-scope flows.
Check the exemption honestly
Compare your headcount and turnover with the microenterprise definition. Write down the result and the date, and revisit it when you grow.
Audit the flows that matter
Test signup, checkout, account management and help against WCAG 2.2 AA. Our article on accessibility audit cost explains scoping.
Fix in code and design
Repair shared components first. Don't install an overlay; as we explain in do accessibility overlays work?, they don't fix the code.
Publish your statement
Explain which standard you meet, what's still broken and how users can get help or an alternative. Link it from the footer and your terms.
Make it part of releases
Add accessibility checks to QA so new features stay compliant.
If you also sell in the US, the same fixes reduce your exposure there; our guide to ADA website compliance covers the differences. And if procurement teams ask about accessibility, add the statement to your B2B trust pages so it's easy to find.
