EN 301 549 is the harmonised European standard setting accessibility requirements for ICT products and services. It is maintained by CEN, CENELEC and ETSI, and it incorporates WCAG 2.1 Level A and AA in full for web content. It is the technical standard European accessibility law points to.

Which version of EN 301 549 applies right now?

V3.2.1, published in March 2021, is the current published version and incorporates WCAG 2.1 Level A and AA. A newer version, V4.1.x, is in final draft and is expected to be cited in the Official Journal around October 2026, moving the baseline to WCAG 2.2.

Does passing an automated scan mean a site conforms to EN 301 549?

No. Automated testing reliably settles roughly a third of WCAG success criteria. It finds missing alternative text, unlabelled controls, contrast failures and structural errors, but it cannot judge whether alt text is meaningful, whether keyboard order makes sense, or whether error messages are understandable. Manual testing is required for a conformance claim.

Do national standards like BITV or RGAA replace EN 301 549?

No. Member States implement European accessibility law nationally, for example BITV 2.0 in Germany and RGAA in France. These national frameworks reference or align with EN 301 549 rather than replacing it, and some add national requirements on top.

EN 301 549 explained: versions, scope, and what changes in 2026

Q: Is EN 301 549 the same as the European Accessibility Act?

No. The European Accessibility Act is the law and states what must be accessible. EN 301 549 is the technical standard that describes how to meet it. Conforming to the harmonised standard gives a presumption of conformity with the law.

A working reference for agencies who have to answer client questions about European accessibility law — without pretending the answers are simpler than they are.

Last reviewed 18 August 2026

In one paragraph: EN 301 549 is the harmonised European standard that sets accessibility requirements for ICT products and services. It is maintained by CEN, CENELEC and ETSI. For websites it incorporates WCAG 2.1 Level A and AA in full. It is not a law — it is the technical standard that European accessibility law points to, and conforming to it gives a presumption of conformity.

Which version applies right now

This is the question that trips people up, because there is a published version and a newer version on the way.

EN 301 549 versions relevant in 2026
Version	Status	WCAG baseline
V3.2.1 (March 2021)	Current published version. The one to test against today.	WCAG 2.1 Level A and AA
V4.1.x	Final draft published by ETSI in 2026. Expected to be cited in the Official Journal around October 2026.	Expected to move to WCAG 2.2

What this means practically

Do not wait for the new version. The European Accessibility Act has been enforceable since 28 June 2025, and V3.2.1 is what exists today. Testing against WCAG 2.1 AA now is the right move.

But if you are scoping remediation work for a client that will run into 2027, budget for WCAG 2.2. The new success criteria are mostly incremental — focus visibility, target size, dragging alternatives, consistent help, accessible authentication — but "we finished accessibility last year" will stop being true when the baseline moves.

What the standard actually covers

EN 301 549 is much broader than WCAG. WCAG covers web content; EN 301 549 covers ICT as a whole. For most agencies only a few clauses matter, but it is worth knowing what else is in there when a client's procurement team sends a questionnaire.

Clause structure, simplified
Clause	Covers	Relevant to a web agency?
5	Generic requirements — closed functionality, biometrics, preservation of accessibility information	Rarely
6	Two-way voice communication	Only if you build calling features
7	Video and audio, including captions and audio description	Yes, if the site carries media
8	Hardware	No
9	Web content — WCAG 2.1 A and AA in full	This is the main one
10	Non-web documents — PDFs, Word files, downloads	Yes, and frequently forgotten
11	Software, including mobile apps	Yes, if you ship apps
12	Documentation and support services	Sometimes — help centres count
13	Relay and emergency service access	No

Clause 10 is the one that catches agencies out. A perfectly accessible website that serves an inaccessible PDF price list still has a problem, and PDFs are almost never in scope when a site is first quoted.

How it relates to the two European laws

There are two different laws, and people constantly conflate them. Keeping them apart makes you sound like you know what you are talking about in a client meeting.

Two laws, one standard
	Web Accessibility Directive (2016/2102)	European Accessibility Act (2019/882)
Who it binds	Public sector bodies	Private businesses offering certain products and services to consumers
Key dates	Websites from 23 September 2020; mobile apps from 23 June 2021	Enforceable from 28 June 2025
Typical clients affected	Municipalities, universities, agencies, public health	E-commerce, banking, transport, telecoms, e-books
Technical standard	EN 301 549 for both

The microenterprise exemption

Under the Accessibility Act, microenterprises providing services — fewer than 10 staff and under €2 million annual turnover — are exempt from several obligations. This matters when you are working out which clients in your portfolio actually need to act. Your smallest clients may not; your mid-sized e-commerce clients almost certainly do.

National implementations

European law is implemented by each Member State, so a client will often be pointed at a national framework rather than the European standard directly. These reference or align with EN 301 549 rather than replacing it, and some add national requirements on top.

Examples of national frameworks
Country	Framework
Germany	BITV 2.0, alongside the Barrierefreiheitsstärkungsgesetz for the Accessibility Act
France	RGAA
Other Member States	National transpositions that reference EN 301 549; penalties and enforcement bodies differ significantly by country

Penalty ceilings vary widely. Published maximums range from tens of thousands of euro in several Member States up to €1,000,000 in Spain. As of mid-2026 there is no publicly verified record of a fine issued specifically under the Accessibility Act — early enforcement has focused on complaints, corrective-action notices and market surveillance.

What automated testing can and cannot tell you

We build automated auditing tools, so it would be convenient for us to overstate this. We are not going to.

Automation settles roughly one third of WCAG success criteria

It is reliable for: missing alternative text, unlabelled form controls and buttons, insufficient colour contrast, missing page language, invalid or unsupported ARIA, structural errors in tables and lists, missing frame titles.

It cannot judge: whether alt text is meaningful, whether the keyboard focus order makes sense, whether an error message is understandable, whether a caption matches the audio, or whether a complex widget is genuinely operable. Those need a human.

The practical consequence: a clean automated report means the machine-detectable barriers are gone. It is a real, defensible milestone and it is what most sites fail on first. It is not a conformance claim, and any vendor who tells you otherwise is selling you a liability.

A practical order of work for agencies

Scope the portfolio. Which clients are actually in scope — sector, size, do they sell to EU consumers? Microenterprise service providers may be exempt.
Run an automated audit first. It is cheap, fast, and clears the majority of findings. Do this before quoting anything, so you are pricing against real numbers.
Fix the design system, not the pages. Contrast and focus styles are usually one token change that clears dozens of instances across every template.
Then do a manual pass on the conversion flow — keyboard only, then a screen reader through checkout or the main form.
Publish an accessibility statement documenting conformance status, known limitations and a feedback channel.
Re-test every release. Accessibility regresses silently with new components and new content. This is the part that becomes a retainer.

Frequently asked

Is EN 301 549 the same as the European Accessibility Act?

No. The Accessibility Act is the law and says what must be accessible. EN 301 549 is the technical standard describing how to meet it. Conforming to the harmonised standard gives a presumption of conformity with the law.

Is WCAG 2.1 AA enough?

For web content under the current version of the standard, yes — clause 9 incorporates WCAG 2.1 Level A and AA in full. Expect the baseline to move to WCAG 2.2 when V4.1.x is cited in the Official Journal, currently anticipated around October 2026.

Do PDFs count?

Yes. Clause 10 covers non-web documents. A downloadable price list, brochure or form is in scope and is one of the most commonly missed items.

Does the Act apply to businesses outside the EU?

It applies to products and services placed on the EU market, including by businesses established outside the EU that sell to EU consumers. Scope depends on national implementing law.

Who decides whether a site conforms?

There is no central certifying authority issuing a pass mark. Conformance is a claim the responsible organisation makes, supported by evidence — audits, remediation records and an accessibility statement. Market surveillance authorities in each Member State can investigate.

See where one of your client sites actually stands

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This page is a plain-language summary for practitioners, not legal advice. Requirements and enforcement differ by Member State — confirm specifics for your client's jurisdiction. Standard texts are published by ETSI, CEN and CENELEC.