Launching an app or SaaS: privacy, consumer and accessibility rules in Australia, the US and EU
Before launching an app or SaaS that collects personal data, you need a privacy policy and data practices that meet each market’s privacy law (GDPR in the EU, the FTC Act and state laws in the US, the Privacy Act in Australia), cookie consent for EU users, compliant subscription and cancellation terms, and accessible design to WCAG 2.2 AA.
Last reviewed 27 October 2026 · A planning guide, not legal or certification advice.
Roadblock lists every step that applies to what you’re launching, for each market, in order.
Privacy
In the EU, the GDPR applies to anyone targeting EU users: a lawful basis for each use of data, clear notices, records of processing, processor agreements, DPIAs for high-risk processing, requests answered within a month and breaches reported within 72 hours. Businesses outside the EU also need an EU representative. In the US, the FTC requires your privacy policy to match what you do and security to be reasonable; about twenty state laws add opt-outs and notices once you pass their thresholds. In Australia, the Privacy Act applies above A$3 million turnover and to smaller businesses that trade in personal information or handle health information, but customers and app stores expect a clear policy regardless.
Cookies and tracking
For EU users, analytics, pixels, SDKs and other non-essential tracking need prior opt-in consent with an equally easy reject option, and you need records of consent.
Subscriptions and consumer law
In Australia, standard form contracts can’t contain unfair terms and renewals and cancellation must be clear. In the US, disclose terms and get express consent before charging, send renewal reminders where state laws require, and make online cancellation as easy as sign-up. EU consumers get pre-contract information, a 14-day withdrawal right (or a valid waiver for digital content) and, from 19 June 2026, a “withdraw from contract” button.
Accessibility and AI
Aim for WCAG 2.2 AA. Since 28 June 2025 the European Accessibility Act applies to e-commerce and other consumer services, except microenterprises. If your product uses generative AI, the EU AI Act requires telling people they’re talking to an AI and marking AI-generated content.
Steps, time and cost
Planning ranges from Roadblock’s register (A$, excluding your own staff time). Which steps apply depends on the product; run an analysis for yours.
| Step | Market | Typical time | Typical cost |
|---|---|---|---|
| GDPR compliance | EU | 4–10 wk | A$3,000–20,000 |
| FTC Act privacy and security | US | 2–4 wk | A$1,500–10,000 |
| Privacy Act and the Australian Privacy Principles | AU | 2–6 wk | A$1,500–10,000 |
| State privacy laws | US | 3–8 wk | A$3,000–20,000 |
| Cookie and tracking consent | EU | 1–3 wk | A$0–3,000 |
| Australian Consumer Law for services and digital products | AU | 1–3 wk | A$1,500–8,000 |
| Online subscription and auto-renewal laws | US | 1–3 wk | A$1,500–8,000 |
| EU consumer rights for online contracts | EU | 2–4 wk | A$1,500–8,000 |
| Digital accessibility (Disability Discrimination Act) | AU | 2–4 wk | A$2,000–15,000 |
| European Accessibility Act (services) | EU | 3–8 wk | A$2,000–15,000 |
| AI Act transparency and literacy | EU | 3–8 wk | A$2,000–15,000 |
| PCI DSS for card payments | All markets | 1–3 wk | A$0–5,000 |
Questions
Does the GDPR apply to my Australian app?
Yes if you offer it to people in the EU or monitor their behaviour, wherever your business is. You’ll likely also need an EU representative.
Does the Australian Privacy Act apply to small businesses?
Generally only above A$3 million annual turnover, but it applies to smaller businesses that trade in personal information, provide health services or contract with government.
Do I need a cookie banner?
For EU users, yes if you use non-essential cookies, analytics, pixels or tracking SDKs. Strictly necessary cookies don’t need consent.
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