Questions · Deadlines and legal requirements
Does the European Accessibility Act apply to a B2B SaaS product?
Usually not directly. The EAA, applied since June 28, 2025, covers listed services “provided to consumers,” such as e-commerce and consumer banking; software sold only to businesses for business use is outside that list. EU public buyers are different: procurement law requires accessibility criteria in their specifications, and EN 301 549 is the standard written for that.
Who the EAA covers
Directive (EU) 2019/882 applies to services provided to consumers after June 28, 2025 (Article 2(2)): electronic communications, access to audiovisual media, parts of passenger transport services, consumer banking, e-books and dedicated software, and e-commerce. A consumer is a person acting “outside his trade, business, craft or profession” (Article 3).
E-commerce services are services provided at a distance “at the individual request of a consumer with a view to concluding a consumer contract.” If individuals can buy your product online for personal use, that sales flow is in scope even when most customers are businesses. Microenterprises providing services — fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total — are exempt from the service requirements (Article 4(5)).
Why EU public buyers still ask
Directive 2014/24/EU, Article 42, requires that for all procurement “intended for use by natural persons, whether general public or staff of the contracting authority,” technical specifications take accessibility criteria into account, except in duly justified cases. EN 301 549 sets out accessibility requirements “in a form that is suitable for use in procurement.”
| Version | WCAG basis | Where it appears |
|---|---|---|
| V3.2.1 (2021) | WCAG 2.1 | ITI’s VPAT® 2.5Rev EU and INT editions |
| V4.1.1 (September 2026) | WCAG 2.2 (clauses 9, 10 and 11) | Adopted August 24, 2026, as one voluntary means of meeting the EAA; it gives a presumption of conformity once cited in the EU’s Official Journal |
Not legal advice
The EAA is a directive: it applies through each member state’s national law. If you sell to consumers in the EU, check the national rules with counsel in the markets you serve.
How ACR Desk handles this
For EU buyers we write the ACR on ITI’s EU edition (EN 301 549 clauses 4 to 13), or on the INT edition, which also covers Section 508 and WCAG in one report: $1,990 fixed, in five business days. If a buyer cites EN 301 549 V4.1.1, tell us with your request and we note in the report how the evaluation maps to it.
Last reviewed: September 30, 2026. Not legal advice: rules change, and your buyer’s solicitation or contract governs what they require.
Sources
Primary sources only. Each was read on September 30, 2026.
- Directive (EU) 2019/882 on the accessibility requirements for products and services (European Accessibility Act) — Articles 2, 3, 4 and 31 — EUR-Lex, Official Journal of the European Union.
- Directive 2014/24/EU on public procurement — Article 42, technical specifications — EUR-Lex, Official Journal of the European Union.
- EN 301 549 V4.1.1 (2026-09) — Accessibility requirements for ICT products and services — ETSI / CEN / CENELEC.
- VPAT® — current version 2.5Rev (April 2025), four editions, FAQs — Information Technology Industry Council (ITI).
- VPAT® 2.5Rev EU edition (April 2025) — EN 301 549 V3.1.1 and V3.2.1 (Word file) — Information Technology Industry Council (ITI).