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SaaS Accessibility Legal Compliance: ADA, EAA & WCAG

David Gibson

If your company sells cloud-based software, such as SaaS or web applications, it’s important to consider the evolving landscape of accessibility requirements. Engaging with a digital accessibility consultant who specializes in manual WCAG compliance testing can be a valuable step. A knowledgeable consultant can help your team navigate auditing, remediation, and verification processes to ensure your platform meets updated ADA, state, and international accessibility laws affecting US-hosted SaaS providers.

In particular, you should be aware of additional laws that take affect soon requiring accessibility compliance with the Web Content Accessibility Guidelines (WCAG). The cost of not complying with these SaaS ADA compliance standards and requirements will soon increase - and not just due to lawsuits, but also in lost sales opportunities.

The two biggest changes for online service providers is first, the updates to ADA Title II that affect SaaS providers servicing state and local governments, and their departments to include schools, libraries and other key public services. This change to the ADA take effect in 2026.

The second is the European Accessibility Act. The EAA applies to any company in the US or otherwise, that  EU citizens can access and use. If you're familiar with impact of the EU's GDPR law governing privacy, then understand that the EAA is the GDPR for all web-based software, websites, mobile apps and content.

While ADA Title II has grabbed the headlines, the EAA may be even more urgent for SaaS providers that offer their web applications across the pond. The EAA's WCAG compliance deadline is coming on fast.  By June 2025 for any SaaS providers with customers in the European Union will need to be WCAG compliant.

Between the update to ADA Title 2 and the EAA, cloud software providers should expect procurement departments to now require a VPAT (Voluntary Product Accessibility Template) to document your compliance. Without these, your SaaS product may not only be non-compliant but may also be disqualified from procurement by government and educational institutions, or those in the EU market.

Even though digital accessibility requirements are nothing new for SaaS providers, the spotlight hasn't been on them up until now. But with these two laws in particular, web-based software providers will now need the assistance of WCAG compliance SaaS consultants to help structure and guide the process of first establishing a program for auditing, remediation, verification, and VPAT authoring, and a longer-term process to ensure on-going compliance.

Here is a summary video on SaaS Compliance

What Are The Accessibility Compliance Standards for SaaS?

The good news is that the ADA, including Title II and Title III, along with other regulations such as Section 508 of the Rehabilitation Act, the Accessibility for Ontarians with Disabilities Act (AODA) in Canada, and the European Accessibility Act, all reference the international standards for digital accessibility: the Web Content Accessibility Guideline.

What is WCAG?

WCAG, established by the W3C (World Wide Web Consortium), outlines a set of guidelines to make digital content accessible to people with disabilities. These guidelines cover a range of requirements, from making text perceivable to ensuring that interactive elements are usable by people with limited mobility or visual impairments. And currently the best method for demonstrating conformity is to provide a VPAT.

What is a VPAT?

A Voluntary Product Accessibility Template is a standardized document born from the .gov procurement world that describes how your digital product complies with WCAG and other accessibility standards, such as Section 508 of the Rehabilitation Act. Government, educational institutions and a growing number of companies require VPATs during their procurement processes, and this requirement is becoming increasingly common. The current version is VPAT 2.5 that covers WCAG 2.2. Failing to provide a VPAT or meet WCAG standards can lead to lost opportunities and significant compliance risks for SaaS providers.

Web App Accessibility Compliance Guide

To ensure your SaaS platform is compliant with WCAG standards and ready for upcoming deadlines, follow these critical steps:

1. Audit Your SaaS Platform for Accessibility

The first step is to understand your current level of compliance. Automated tools are helpful for catching some low-hanging fruit—like missing alt tags or improper headings—but they can only detect about 30% of WCAG violations at best. A comprehensive audit demands manual testing by human experts who can evaluate the usability of your platform for real people with disabilities, covering areas that automated scans simply miss.

What about AI? Can't AI powered testing tools accurately audit SaaS?

Yes this is certainly coming, it is not here. While most automated WCAG testing providers will make grand claims of their AI, fact is, these are not yet using modern LLM Generative AI models like ChatGPT. And the AI used simply cannot mimic the use cases of real people with disabilities and the nuances of their needs. Human  auditors that provide manual SaaS WCAG testing for ADA and EAA compliance will be required still for some time.

2. Remediation and Accessibility Improvements

After identifying accessibility issues during the audit, the next step is remediation. This may include updating your platform’s front-side code, ensuring navigability through a keyboard-only interface, or adding multimedia content captions and transcripts. The good news is that such software is built using common templates and components that reduce the cost of remediation. Remediation isn't just about avoiding lawsuits; it’s about creating an inclusive experience that benefits all users, enhances usability, and improves your brand reputation. 

Remember, accessibility is the pinnacle of usability. 

3. VPAT Creation

Once your platform meets the required standards, you'll need to produce a VPAT. This document acts as proof that your SaaS product complies with WCAG standards—essential for government and educational procurement. Accessibility.Works specializes in auditing SaaS platforms and providing the documentation necessary to help you meet and even surpass procurement requirements, allowing you to expand your client base.

Why Compliance Matters for SaaS Providers: Revenue, Reputation, and Legal Risks

The stakes are high for SaaS providers targeting the education and government sectors in particular. Here's why compliance should be on your radar:

  • Client Demand: Government agencies and educational institutions are increasingly making VPATs a non-negotiable part of their procurement processes. If your product doesn’t have a VPAT or isn’t fully compliant, you may be automatically disqualified from bidding opportunities.
  • Legal Risks: Compliance with laws like ADA Titles II and III, Section 508, and other accessibility regulations here and abroad is not optional; it’s a legal requirement. Failing to meet these requirements can open your company up to lawsuits, which can be costly and damage your reputation. The risk of legal action for non-compliance is real and growing, with numerous examples already demonstrating the consequences of neglecting accessibility requirements.
  • Reputation and Inclusivity: Inaccessible software can alienate  both users with disabilities and Seniors. Seniors in particular are often overlooked, yet this is a huge market - with over \$548 Billion in disposable income.

But the impact goes beyond that. As diversity, equity, and inclusion (DEI) initiatives become more central to organizational values, accessibility is increasingly seen as an essential element rather than a luxury. Meeting these standards enhances your company’s reputation and demonstrates your commitment to all users.

Get Ahead of Accessibility Deadlines: Start in on SaaS WCAG Compliance Today

Needless to say, there is little time to waste. While the time to audit is quite fast, you know how long remediation can take.

Be Proactive with Accessibility Audits: Conducting a proper manual accessibility audit of your SaaS today can not only provide a clear view of the scope of remediation, but also provide prioritization guidance. Its essential to prioritize Critical and Serious WCAG barriers first. Addressing these in an organized and prioritized process will ensures reduced legal exposure, and optimal use for users.

Ongoing Maintenance Is Key: Achieving compliance is not a one-time task. Technology changes, user needs evolve, and standards are updated. Regular audits and updates are essential to maintain WCAG compliance over time. Building this into your maintenance process ensures long-term success.

At Accessibility.Works, we specialize in both WCAG audits and VPAT creation. Our senior-level experts, with decades of experience, can help you navigate the intricacies of digital accessibility. Unlike companies that rely on quick fixes or AI-powered "solutions", we provide thorough, human-centric accessibility solutions tailored for SaaS providers.

Beyond Compliance: The Benefits of Accessibility for Your SaaS Platform

Meeting WCAG standards offers much more than just compliance. Here are some significant benefits:

  • Enhanced User Experience: Accessible design improves usability for everyone, not just people with disabilities. Thoughtful design makes navigation more intuitive and content easier to engage with, ultimately benefiting all users.
  • Expanded Market Reach: Compliance with accessibility standards opens your product to a broader audience, including aging populations and individuals with disabilities. This not only grows your user base but also positions your company as inclusive and socially responsible.
  • Competitive Advantage: By addressing accessibility issues proactively, you distinguish your SaaS from competitors who may be slower to adapt. This can be a significant differentiator in markets that value inclusivity and user experience.

Wrap Up.

The accessibility deadlines are fast approaching, but you still have time if you start now and are disciplined not to fall for short-cuts. If you take a phased priority-based  approach, you can meet whatever deadline you face. 

And we can help.