PCA-Net is a recently proposed neural operator architecture which combines principal component analysis (PCA) with neural networks to approximate operators between infinite-dimensional function spaces. The present work develops approximation theory for this approach, improving and significantly extending previous work in this direction: First, a novel universal approximation result is derived, under minimal assumptions on the underlying operator and the data-generating distribution. Then, two potential obstacles to efficient operator learning with PCA-Net are identified, and made precise through lower complexity bounds; the first relates to the complexity of the output distribution, measured by a slow decay of the PCA eigenvalues. The other obstacle relates to the inherent complexity of the space of operators between infinite-dimensional input and output spaces, resulting in a rigorous and quantifiable statement of the curse of dimensionality. In addition to these lower bounds, upper complexity bounds are derived. A suitable smoothness criterion is shown to ensure an algebraic decay of the PCA eigenvalues. Furthermore, it is shown that PCA-Net can overcome the general curse of dimensionality for specific operators of interest, arising from the Darcy flow and the Navier-Stokes equations.