European Accessibility Act · Ireland

Is your SaaS accessible?

S.I. 636/2023 applies the European Accessibility Act to SaaS sold to consumers in Ireland — B2C and B2B2C/prosumer products — since 28 June 2025, against WCAG 2.1 AA. SaaS fails in specific places: sign-up/onboarding, dashboards and complex data tables, filter/sort controls, modals, and focus management in single-page apps. Ireland is the only EU state with criminal liability. Pure B2B-only tools may fall outside consumer scope — but most SaaS has consumer or prosumer users.

SaaS & the EAA at a glance

Law: S.I. 636/2023 — Directive (EU) 2019/882
In force: 28 June 2025
Applies to SaaS: yes — B2C and B2B2C/prosumer; pure B2B-only may be out of scope
Standard: EN 301 549 → WCAG 2.1 Level AA
Liability: criminal — up to €60,000 or 18 months
Exemption: microenterprises (under 10 staff AND under €2M turnover)

Where does a SaaS product fail WCAG 2.1 AA?

The failures cluster in the parts of an app a marketing site doesn't have:

Sign-up & onboarding: inputs without programmatic labels, validation errors shown only in colour and never announced, multi-step wizards with no progress semantics.
Dashboards: no landmark regions, illogical tab order, widgets that can't be reached or operated by keyboard.
Data tables: missing <th> scope, sortable columns that don't announce their sort state.
Filter & sort controls: custom dropdowns built from <div>s with no ARIA.
Modals: focus not trapped, background still reachable, focus not returned on close.
Charts: canvas/SVG with no text alternative.
Session timeout: sessions that expire with no warning and no way to extend (WCAG 2.2.1).

Does the EAA apply to B2B SaaS?

The EAA covers services provided to consumers. Clearly in scope: B2C apps and B2B2C/prosumer tools where individuals sign up. A pure B2B-only product with no consumer-facing surface may fall outside consumer scope — but a public self-serve sign-up or free tier usually pulls it back in. Don't over-claim an exemption you can't defend.

What breaks in single-page apps (React, Vue)?

Client-side route changes don't move focus or update the accessibility tree, so screen-reader users are left on a stale page with no announcement — fix it by moving focus to the new view's heading and announcing via an ARIA live region. Custom widgets frequently create keyboard traps.

How do you audit a SaaS product behind a login?

An automated scan only sees public pages. We combine it with a manual audit of the authenticated flows — sign-up, onboarding, core task flows, dashboards — with a screen reader (NVDA / VoiceOver) and keyboard, using test credentials or a staging environment. You get fix tickets and a dated certificate. Start with the free scan below.

Is your app compliant?

Free

Your app, checked against WCAG 2.1 AA.

FAQ

Does the EAA cover my SaaS app?

If consumers or prosumers can sign up and use it, yes — since 28 June 2025, against WCAG 2.1 AA. B2C and B2B2C are in scope. A public self-serve sign-up usually brings a "B2B" tool back in.

Our app is behind a login — is that still covered?

Yes. The obligation covers the whole service, including authenticated flows — where most failures live.

What are the most common SaaS accessibility failures?

Unlabelled form fields and colour-only errors, keyboard-inoperable custom dropdowns and modals, data tables without header semantics, and SPA route changes that never move focus.

How do you test flows behind authentication?

With test credentials or a staging environment we manually drive the real authenticated journeys with a screen reader and keyboard, and deliver fix tickets plus a dated certificate.