The European Accessibility Act for SaaS and Web Apps: What to Test

The European Accessibility Act has applied since 28 June 2025 to consumer-facing services sold in the EU, including e-commerce, consumer banking, e-books, electronic communications and parts of passenger transport. A SaaS or web app is covered if it delivers one of those services to consumers, or powers one for your customer. Test it against WCAG 2.2 AA, the baseline of the new EN 301 549.

This is general information, not legal advice; confirm with your adviser how the Act applies to your product. If you would rather have the testing done for you, see how RAITHub would test this near the end.

What is the European Accessibility Act?

It is Directive (EU) 2019/882, which sets common accessibility requirements for a list of products and services across EU member states (Directive (EU) 2019/882 on EUR-Lex). Each member state wrote it into national law, and national authorities enforce it and set the penalties. The rules have applied since 28 June 2025 (European Commission: European Accessibility Act).

It applies by what you sell and to whom, not where your company is based. A company in the US, UK or Bangladesh that offers a covered service to consumers in the EU is in the same position as an EU company.

Does the European Accessibility Act apply to my SaaS?

It depends on whether a consumer uses your product to receive one of the listed services. The Directive covers products such as computers, smartphones and self-service terminals, and these services:

• electronic communications services
• services giving access to audiovisual media
• elements of air, bus, rail and waterborne passenger transport, such as websites, apps, e-tickets and real-time travel information
• consumer banking services
• e-books and the software used to read them
• e-commerce services: services provided at a distance, through websites and apps, at a consumer's request, with a view to concluding a consumer contract

Your product	Likely position	Why
Online shop, marketplace or subscription checkout selling to EU consumers	Likely in scope	It is an e-commerce service
White-label storefront, booking or banking front end that your customers offer to consumers	Likely pulled in through your customers	Your customer is the service provider, and needs your product to meet the requirements
Consumer app that sells subscriptions or digital goods in-app	Possibly in scope	The purchase flow may count as e-commerce
B2B tool used only by staff (CRM, HR, internal analytics)	Usually outside the Act	No consumer service is delivered, though public-sector and procurement rules may still ask for accessibility
Service run by a microenterprise	Exempt from the service requirements	See the exemption below

The middle rows are where SaaS companies get surprised. Even if the Act does not name you, a bank, retailer or airline customer may make WCAG 2.2 AA a contract term and ask you for an audit report or conformance report. Treat this table as a starting point for a conversation with your adviser, not a ruling.

Who is exempt from the European Accessibility Act?

Three routes, each narrower than people hope (Directive (EU) 2019/882):

• Microenterprises providing services. A microenterprise has fewer than 10 people and either an annual turnover or a balance sheet total of no more than EUR 2 million. Those providing services are exempt from the service requirements. Microenterprises making products are not.
• Disproportionate burden or fundamental alteration. A provider may rely on this only after a documented assessment, and must still meet the requirements to the extent it can.
• Transition periods. Service providers may keep using products they lawfully used before 28 June 2025 until 28 June 2030, and service contracts agreed before 28 June 2025 can continue unchanged until they expire, for no longer than five years from that date.

None of these is a reason to skip testing on a growing product. A company that crosses the microenterprise thresholds, or wins a customer that needs evidence, needs the work done anyway. General information; confirm with your adviser.

Which standard proves accessibility: EN 301 549 or WCAG 2.2?

Both, in sequence. The Act sets functional requirements. A harmonised European standard, EN 301 549, translates them into tests; meeting it gives a presumption of conformity. Version 3.2.1 used WCAG 2.1 AA for web content. Version 4.1.1, published on 2 September 2026, moves web, document and software requirements to WCAG 2.2 AA (National Disability Authority, Ireland). It takes on that legal role once the Commission cites it in the Official Journal, which Deque expected around the end of November 2026 and the Irish National Disability Authority on 16 December 2026 (Deque on EN 301 549 v4.1.1).

The practical answer: test to WCAG 2.2 AA now. It includes everything in 2.1 AA except the removed Parsing criterion, plus six new A and AA criteria (W3C: What's new in WCAG 2.2).

What should a SaaS team actually test for the EAA?

The journeys a consumer uses to find, buy, use and leave the service. For a typical SaaS or e-commerce product:

Journey	What to test	WCAG 2.2 focus
Sign-up and login	Labels, errors, password managers, one-time codes, CAPTCHA alternatives	3.3.8 Accessible Authentication, 3.3.1, 1.3.5
Product discovery and search	Filters by keyboard, results announced, headings and landmarks	2.1.1, 4.1.3, 1.3.1
Checkout and payment	Field labels, error recovery, third-party payment frames, time-outs	3.3.1 to 3.3.3, 3.3.7, 2.2.1
Core workflow	Custom widgets, drag-and-drop alternatives, target size, focus visibility	2.5.7, 2.5.8, 2.4.11, 4.1.2
Account, billing and cancellation	Reachable by keyboard and screen reader, same as sign-up	2.1.1, 2.4.3
Help and support	Help in a consistent place; support channels themselves accessible	3.2.6 Consistent Help
Accessibility information	A published statement of how the service meets the requirements	Annex V of the Directive

The last row is easy to miss. Annex V of the Directive asks service providers to publish information on how the service meets the accessibility requirements, for example in the general terms and conditions. Your audit report is the raw material for that statement.

Third-party components count: an embedded payment form, chat widget or cookie banner that traps the keyboard breaks your checkout journey. Test them in place, and raise defects with the vendor.

The page-by-page manual checks are in our accessibility testing checklist for web apps.

How do you keep EAA evidence current after the first audit?

An audit is a snapshot; a SaaS changes weekly. Put an automated gate in CI so obvious regressions fail the build, and repeat a manual pass on each release that changes UI. A minimal check with Playwright and axe-core (Playwright accessibility testing docs):

import { test, expect } from '@playwright/test'
import AxeBuilder from '@axe-core/playwright'

const consumerJourney = ['/', '/search?q=shoes', '/cart', '/checkout']

for (const path of consumerJourney) {
  test('WCAG 2.2 A/AA automatic checks: ' + path, async ({ page }) => {
    await page.goto(path)
    const { violations } = await new AxeBuilder({ page })
      .withTags(['wcag2a', 'wcag2aa', 'wcag21a', 'wcag21aa', 'wcag22aa'])
      .analyze()
    expect(violations.map((v) => v.id)).toEqual([])
  })
}

Keep the dated audit report, the retest, the CI history and the published accessibility statement together. If an authority or customer asks, that bundle shows a process, not a one-off fix. Automated checks cover only part of WCAG, so the manual pass still matters; the 2026 WebAIM Million found detectable failures on 95.9% of home pages, before any manual testing (WebAIM Million 2026).

Buy, build or hire?

Option	Choose this when	What it will not give you
A tool or SaaS testing platform	You want continuous scanning across many pages and a dashboard	Manual WCAG 2.2 checks, or an issue-by-issue fix list
Freelancers or crowdtesting	You want a one-off manual pass or feedback from disabled users	Consistent reporting and CI gates
An in-house QA hire	You release consumer-facing UI every week	Instant expertise; specialists are hard to hire
A managed QAaaS team	You want an audit, fixes per issue, retest and ongoing checks	A legal opinion; you still need an adviser for that

Market prices for each are in accessibility audit cost.

When don't you need RAITHub for this?

• When the question is legal: whether you are in scope, exempt, or can claim disproportionate burden. Ask a lawyer who knows the national law in your markets.
• When a customer demands a certificate or a signed attestation. RAITHub reports against WCAG 2.2 AA and does not certify legal compliance.
• When your product is an internal B2B tool with no consumer users and no customer asking for evidence. A scanner in CI may be all you need for now.

How RAITHub would test this

RAITHub's accessibility testing service, part of QA as a service, would:

• map the consumer journeys, roles and third-party components in scope, using the table above
• audit them against WCAG 2.2 AA with axe-core and manual keyboard, focus, screen reader, zoom and authentication checks
• report each issue with its success criterion, severity, steps to reproduce and a specific fix, which your team can turn into the published accessibility statement
• add accessibility checks to your automated test suite in your CI, and retest after your fixes

Buy it as a fixed-price one-off audit, within a monthly QA plan, or with a dedicated QA team that RAITHub manages. Testers are never placed under your management. The audit does not certify compliance with the EAA, the ADA or Section 508; it gives you the technical evidence your adviser and customers will ask for. RAITHub has no accessibility case study yet, so ask for a sample report on the free 15-minute call, after which you receive a written fixed quote. Request an accessibility audit.

Frequently asked questions

When did the European Accessibility Act start to apply?

On 28 June 2025. Transition periods let service providers keep using products already in use until 28 June 2030, and existing service contracts continue for up to five years. General information; confirm with your adviser.

Does the European Accessibility Act apply to B2B SaaS?

The Act lists consumer services, so a purely internal B2B tool is usually outside it. A SaaS product that delivers e-commerce, banking, transport or similar services to consumers on your customer's behalf can be pulled in. Confirm with your adviser.

Does the EAA apply to companies outside the EU?

Yes, if they provide a covered service to consumers in the EU. Where the company is based does not decide it.

Is WCAG 2.1 still enough for the EAA?

EN 301 549 v3.2.1 references WCAG 2.1 AA, but v4.1.1, published in September 2026, moves to WCAG 2.2 AA and is expected to be cited in the Official Journal in late 2026. Testing to 2.2 AA now avoids a second audit.

Can RAITHub certify that my app complies with the EAA?

No. RAITHub audits against WCAG 2.2 AA and reports each issue with its fix. Legal compliance is a question for your adviser.

What is the microenterprise exemption?

Businesses with fewer than 10 people and an annual turnover or balance sheet total of no more than EUR 2 million are exempt from the service requirements. It does not cover products. General information; confirm with your adviser.