Regulatory context
While 'SaaS' is not explicitly named in the EAA, many SaaS products fall within scope through their sector classification - e-commerce platforms, financial services, communication tools, and ticketing systems are all covered. Additionally, the EAA covers 'services providing access to audiovisual media' and 'e-commerce services' broadly, which captures many SaaS products. For B2B SaaS selling to EU enterprises and public sector, accessibility is increasingly a procurement requirement regardless of EAA classification - buyers request VPATs and EN 301 549 conformance reports.
Common issues Lumi finds in saas & software websites
Custom UI component accessibility
SaaS products are built with complex custom components - drag-and-drop interfaces, rich text editors, data grids, kanban boards, dashboards. These custom components almost always lack proper ARIA roles, keyboard navigation, and screen reader support.
Single-page application navigation
SaaS apps built as SPAs (using React, Angular, Vue) handle navigation client-side. Without proper focus management and route change announcements, screen reader users lose their place when views change and don't know new content has loaded.
Real-time collaboration features
Live cursors, presence indicators, real-time edits, and notification systems need to announce changes to screen readers without being overwhelming. Most SaaS apps either don't announce changes at all or create a flood of announcements.
Onboarding and tour modals
Product tours, onboarding flows, and feature announcements frequently use modal dialogs, tooltips, and overlay elements that trap focus incorrectly, can't be dismissed with keyboard, or are invisible to screen readers.
Settings and configuration interfaces
Complex settings pages with toggles, nested options, conditional fields, and permission matrices are often built with custom controls that lack proper labels, state announcements, and keyboard interaction patterns.
SaaS & Software-specific challenges
SaaS products face unique accessibility challenges because of their application-like interfaces. Unlike informational websites, SaaS products have complex interactive workflows that must be fully operable by keyboard and screen readers. Rapid development cycles and frequent deploys mean accessibility can regress with any release. Third-party integrations and embedded content (Stripe checkout, intercom chat, calendar widgets) introduce accessibility issues outside the team's direct control. Design systems need accessibility built in from the component level to scale across the product.
Compliance timeline
The EAA is enforceable from 28 June 2025 for in-scope services. For B2B SaaS, even if the EAA doesn't directly apply, EU public sector procurement increasingly requires EN 301 549 conformance. VPATs (Voluntary Product Accessibility Templates) and ACRs (Accessibility Conformance Reports) are becoming standard parts of enterprise sales processes.
Check your saas & software site now
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Frequently asked questions
Does the EAA apply to SaaS products?
It depends on the sector. SaaS products that provide e-commerce, financial services, telecommunications, or media services to EU consumers are in scope. B2B SaaS may not be directly covered but faces growing accessibility requirements through EU procurement standards.
What WCAG level does SaaS need?
EN 301 549 (referenced by the EAA) incorporates WCAG 2.1 Level AA for web content. For software applications, EN 301 549 includes additional requirements beyond WCAG covering software-specific interaction patterns, documentation, and support services.
Do we need a VPAT for EU sales?
Increasingly, yes. EU enterprise and public sector buyers request VPATs or EN 301 549 conformance reports as part of procurement. While not legally required for all SaaS sales, having a current VPAT significantly smooths enterprise sales cycles in EU markets.
How do we maintain accessibility with frequent releases?
Automated accessibility testing in CI/CD pipelines catches regressions before they ship. Lumi integrates into your development workflow to scan staging environments and flag new issues before they reach production.
Related resources
Last reviewed: April 2026. Content is reviewed quarterly for accuracy.