EAA readiness audit
EAA Readiness Audit for French SaaS Products
The European Accessibility Act deadline of 28 June 2025 applies to digital services placed on the EU market, including SaaS products serving French consumers. Behavioural research with neurodivergent testers gives you documented evidence of where your product meets the standard and where it does not.
French SaaS Teams Face a Concrete Compliance Deadline and a Real Usability Gap
EU Directive 2019/882, the European Accessibility Act, sets 28 June 2025 as the date from which accessibility requirements apply to products and services placed on the market. French SaaS products that serve consumers, including B2C subscription tools, e-commerce platforms, and consumer-facing banking or e-book services, fall within the scope of the directive as transposed into French law. B2B-only SaaS products sold exclusively to professional buyers sit outside the EAA's consumer-service scope, but many French SaaS businesses serve a mixed audience and should assess their exposure carefully before assuming they are exempt.
The gap between passing an automated accessibility checker and delivering a genuinely usable product is wide. RGAA, the French national accessibility reference framework, sets technical criteria, but criteria alone do not tell you whether a neurodivergent user can complete a free-trial sign-up, navigate a pricing page, or reach a support ticket form without abandoning. Those are the journeys where usability failures become compliance evidence and where they cost you revenue.
OpenScouter runs remote testing sessions with neurodivergent participants, capturing interaction signals, think-aloud voice, and facial expression in parallel. The AI pipeline correlates the three streams. A human researcher confirms every finding before it reaches you. The result is a report your legal, product, and design teams can act on, not a spreadsheet of WCAG violations with no context.
Member States shall apply the accessibility requirements from 28 June 2025 for products and services placed on the market, including e-commerce, banking, e-books and audiovisual media services
For French SaaS products, the significance of EU Directive 2019/882 is that it converts accessibility from a best-practice aspiration into a time-bound market requirement. The 28 June 2025 date is not a distant horizon; it is a fixed point against which French SaaS businesses serving consumers need to assess their current product state. Critically, the directive's scope includes e-commerce and related digital services, which means many French SaaS products with consumer-facing subscription or onboarding flows need to consider their position carefully, while pure B2B products sold only to professional buyers should take legal advice before assuming they are outside scope. Behavioural research is the evidence method that bridges the gap between a technical RGAA audit and documented proof that real users can complete the journeys the directive is designed to protect.
Our approach
Scope Assessment Before Testing Begins
We start by mapping which parts of your product are in scope under the EAA as it applies to consumer-facing digital services in France. B2B-only flows are noted separately. We then agree the test journeys, typically free-trial registration, onboarding, and account management, because those are the flows most likely to surface both usability failures and compliance gaps.
Three-Stream Behavioural Capture With Neurodivergent Testers
Participants from our panel, people with ADHD, dyslexia, autism, and low vision, complete the agreed journeys on your live product. We capture clicks, scrolls, and rage clicks alongside think-aloud voice and locally processed facial expression data. Neurodivergent testers surface friction that neurotypical users overlook, making them a higher-signal panel for both usability and accessibility evidence.
Human-Confirmed Report Mapped to EAA Criteria
An AI pipeline correlates the three data streams and flags candidate findings. A human researcher reviews every finding before it enters your report. Findings are mapped to the relevant EAA functional requirements and, where applicable, to RGAA criteria. The report is evidence of observed behaviour, not legal opinion. Your legal counsel determines compliance status; we give them documented, reproducible findings to work with.
What you receive
- Scope memo confirming which product flows are assessed as consumer-facing and therefore within EAA scope, with a note on any flows excluded as B2B-only
- Annotated session recordings showing interaction signals, voice commentary, and facial expression data for each neurodivergent participant
- AI-correlated findings report, human-confirmed, mapping observed usability failures to EAA functional requirements and relevant RGAA criteria
- Prioritised issue list ordered by severity and journey impact, covering free-trial sign-up, onboarding, and account management flows
- Written recommendations your design and engineering teams can act on in the next sprint, without requiring specialist accessibility consultants to interpret them
Frequently asked
- Does the EAA apply to our French SaaS product?
- The EAA, EU Directive 2019/882, applies to products and services placed on the EU market that fall within its defined categories, which include e-commerce, banking, e-books, and audiovisual media services. If your SaaS product serves consumers in those categories, it is likely in scope. Pure B2B SaaS sold only to professional buyers is generally outside the directive's consumer-service scope. If your product serves a mixed audience, you should take legal advice on your specific exposure. OpenScouter's scope memo at the start of an engagement documents which flows we are treating as in scope and why, but it is not a legal opinion.
- We already have an RGAA audit. Why do we need behavioural research as well?
- RGAA audits check technical criteria against the French national accessibility reference framework. They tell you whether specific code and content attributes meet the standard. They do not tell you whether a neurodivergent user can actually complete a journey on your product. Behavioural research captures what happens when a real person with ADHD or dyslexia attempts your free-trial sign-up. The two methods are complementary. An RGAA audit without behavioural evidence leaves gaps that regulators and users will find.
- What kinds of usability failures do neurodivergent testers typically surface in SaaS products?
- In SaaS onboarding flows, common findings include form fields that lose state unexpectedly, error messages that do not explain what went wrong, navigation structures that require users to hold too many steps in working memory, and timeout behaviours that penalise slower readers. These are not edge cases. They affect a significant share of your user base and they drive drop-off at exactly the points where you are trying to convert or retain customers.
- How long does an EAA readiness audit take?
- A focused audit covering three to four key journeys, typically free-trial registration, onboarding, and account management, takes around two to three weeks from study brief to delivered report. That includes panel recruitment, session scheduling, AI correlation, and human confirmation of findings. If your 28 June 2025 deadline is approaching, contact us early so we can confirm availability.
- Are your reports suitable for sharing with our legal team or a French regulator?
- Yes, with an important caveat. Our reports document observed user behaviour, mapped to EAA functional requirements and RGAA criteria where relevant. They are evidence of what neurodivergent users experienced on your product. They are not legal opinions and do not constitute a compliance certification. Your legal counsel uses our findings as documented evidence when assessing your position. We are deliberately specialised in the behavioural evidence layer, not the legal interpretation layer.
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