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Blog/European Accessibility Act Fines: What US SaaS Companies Must Do Now
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European Accessibility Act Fines: What US SaaS Companies Must Do Now

The European Accessibility Act has applied since June 2025. Here's whether your US SaaS or store is covered, who enforces it, how fines work, and a practical plan.

Updated October 4, 2026
6 min read

If your US company sells covered digital services to consumers in the EU, the European Accessibility Act (EAA) applies to you, even with no EU office. It has applied since 28 June 2025, is enforced country by country by national authorities, and fines are set by each member state (Germany's law allows up to €100,000 per violation). The practical fix is to bring your customer-facing product to WCAG 2.1 Level AA, publish accessibility information, and fix reported barriers quickly.

This is general information, not legal advice. EU rules vary by country, so check with counsel for your specific situation.


Does the EAA apply to my US company?

The EAA (Directive (EU) 2019/882) covers specific products and services offered to consumers in the EU. Where your company is based doesn't matter. Who your customers are and what you sell does.

Services in scope include:

  • E-commerce services: any website or app that sells products or services to consumers online
  • Consumer banking services
  • E-books and dedicated reading software
  • Electronic communications services
  • Websites, apps and ticketing for passenger transport (air, bus, rail, waterborne)

What this means for SaaS:

Your situation Likely covered?
Online store or checkout selling to EU consumers Yes, as an e-commerce service
B2C subscription app sold online to EU consumers Often yes, because the online sale is an e-commerce service
Pure B2B SaaS sold only to businesses Generally outside the EAA's consumer scope, but EU public-sector and enterprise buyers often require EN 301 549 conformance in contracts anyway
Microenterprise (fewer than 10 staff and annual turnover or balance sheet of €2 million or less) providing services Exempt from the service requirements

If you're unsure which row you're in, assume the customer-facing parts of your product (sign-up, checkout, account pages, support) should meet the standard. That's also where your buyers will notice first.


Who enforces the EAA, and how big are the fines?

Each EU member state turned the directive into national law and appointed market surveillance authorities to enforce it. The European Commission does not issue EAA fines itself.

The directive only requires penalties to be "effective, proportionate and dissuasive," so amounts vary. Germany's implementing law, the Barrierefreiheitsstärkungsgesetz (BFSG), allows fines of up to €100,000. Authorities can also order you to fix a service or, in serious cases, stop offering it. In some countries consumer and disability organisations can also take action.

Enforcement in the first year has mostly been complaint-driven. That makes a working feedback channel especially valuable: a complaint you resolve yourself rarely reaches a regulator.


What the EAA requires in practice

1. Meet the technical standard

The EU harmonised standard is EN 301 549. Its web chapter maps directly to WCAG 2.1 Level AA, so if you're already working toward WCAG for the US market, you're doing the same work. Start with the most common failures:

  • Text contrast of at least 4.5:1 (WCAG 1.4.3)
  • Text alternatives for images (1.1.1)
  • Labels for every form field (1.3.1, 3.3.2)
  • Full keyboard access with visible focus (2.1.1, 2.4.7)
  • Correct names and roles for custom controls (4.1.2)

A free automated scan will show you where you stand on the machine-detectable items.

2. Publish accessibility information

Annex V of the directive requires service providers to explain how their service meets the accessibility requirements. Most companies do this with an accessibility statement linked from the footer, covering:

  • Which standard you follow (EN 301 549 / WCAG 2.1 AA)
  • What isn't accessible yet, and your plan to fix it
  • How to report a barrier, and how fast you respond
  • The enforcement authority a user can complain to, where relevant

3. Fix the product, not just the marketing site

Many SaaS teams polish the landing page and forget the app. Prioritise the flows a consumer must complete: sign-up, login, checkout, billing, account settings and cancellation. In React or Next.js apps, the most common failures are unlabeled icon buttons, custom dropdowns that ignore the keyboard, and modals that don't manage focus:

<!-- A modal that screen readers and keyboards can use -->
<div role="dialog" aria-modal="true" aria-labelledby="plan-title">
  <h2 id="plan-title">Change plan</h2>
  <!-- move focus here on open, trap Tab inside, return focus on close -->
  <button type="button">Confirm</button>
  <button type="button">Cancel</button>
</div>

The native <dialog> element with showModal() handles most of this for you in modern browsers.

4. Keep it accessible

Weekly releases mean weekly regressions. Add automated accessibility checks to CI (for example @axe-core/playwright), re-scan production on a schedule, and keep a dated record of what you fixed.


A 30-day plan for US SaaS teams

  1. Week 1: Decide whether you're in scope (table above). Scan your marketing site and the key app flows.
  2. Week 2: Fix contrast, labels, alt text, button names and page language across shared components. These fixes spread everywhere the component is used.
  3. Week 3: Do a keyboard and screen reader pass through sign-up, checkout and account settings. Fix focus management in modals and menus.
  4. Week 4: Publish your accessibility statement with a reporting contact, add accessibility tests to CI, and schedule ongoing scans.

Where Accessibility Shield fits

Accessibility Shield scans your pages weekly with axe-core in a real browser, flags new issues with the WCAG criterion and a code-level fix (plus a prompt for AI coding tools like Cursor and Claude Code), and hosts an accessibility statement with a barrier reporting form. It covers the automated testing and documentation side of EAA readiness. Manual testing and product fixes are still yours. Start with a free scan or read our broader European Accessibility Act guide.


Frequently asked questions

When did the European Accessibility Act take effect?

The EAA has applied since 28 June 2025. Some services that use products already in use before that date have transition periods running until 2030, but new services and websites are expected to comply now.

Does the EAA apply to companies outside the EU?

Yes. It applies to covered products and services offered to consumers in the EU, wherever the company is based.

Is B2B SaaS covered by the EAA?

Generally not, if it's sold only to businesses and isn't one of the listed services. But EU public-sector buyers and many large companies require EN 301 549 conformance in procurement, so accessibility still matters commercially.

What standard does the EAA use?

The harmonised standard is EN 301 549, whose web requirements match WCAG 2.1 Level AA.

Are small businesses exempt from the EAA?

Microenterprises (fewer than 10 employees and annual turnover or balance sheet total of €2 million or less) that provide services are exempt from the service accessibility requirements. Larger small businesses are not.

Tags:
#European Accessibility Act
#EAA Fines
#EAA Compliance
#SaaS Accessibility
#EN 301 549
#WCAG 2.1 AA

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