# Selling to the US and EU: Accessibility Rules Indian Exporters Must Meet

> Updated 2026-10-25 - 10 min read

Indian IT services firms, SaaS companies and BPOs building for US and EU clients face accessibility obligations that have nothing to do with Indian law - they attach based on where the product is sold, not where it's built. This guide lays out what the ADA, Section 508 and the European Accessibility Act actually require, and how to meet all three without three separate testing efforts.

## Why your client's jurisdiction is what matters, not yours

This is the same extraterritorial logic that made GDPR a global concern rather than a European one, and it's now repeating with accessibility law. If your product is sold to US or EU users, the obligations attach to that sale - regardless of where your company is incorporated or where your developers sit.

## The three frameworks, compared

- ADA (Title III, private sector; Title II for US government with April 2027/2028 deadlines) - litigation-risk driven, WCAG 2.1 AA as the practical baseline, no formal certification, a VPAT as the usual evidence buyers ask for.
- Section 508 - specifically for US federal procurement, WCAG 2.0 AA via the Revised 508 Standards, a VPAT/ACR required before a federal contract is awarded.
- European Accessibility Act (in force since June 28, 2025) - covers e-commerce, consumer banking, e-books, transport and telecom sold in the EU, with EN 301 549 as the technical standard and enforcement handled nationally by each member state.

## One testing pass, three reports

WCAG 2.2 AA manual testing underlies all three frameworks. What differs is the documentation format - which VPAT edition a buyer expects - and a handful of criteria-specific gaps, like EN 301 549's non-web requirements around documentation and support services that WCAG alone doesn't cover.

## What your contract and sales team should know

Your US or EU client's procurement team will very likely ask for a VPAT before signing. If you built the product, their accessibility exposure traces back to your delivery - which makes this a sales-enablement issue as much as a compliance one.

## FAQ

**Do we need separate audits for the US and EU?**
No - one WCAG 2.2 AA testing pass covers the technical core for all three frameworks; we then produce the specific documentation format (VPAT edition) each buyer needs.

**Does being an Indian company change any of this?**
No - all three frameworks apply based on who you're selling to or serving, not where your company is incorporated.