EN 301 549: the European standard, WCAG and the EAA

What EN 301 549 is, and how it relates to WCAG

EN 301 549 is titled "Accessibility requirements for ICT products and services". It is a European standard published by CEN, CENELEC and ETSI, and it was written so that public bodies could put accessibility into procurement. It covers far more than websites: hardware, software, non-web documents, telephony, video, documentation and support services each have their own chapter.

For the web, the answer is short. Chapter 9 of V3.2.1 restates the WCAG 2.1 Level A and AA success criteria, one clause per criterion. The standard says it in its own words: conformance with WCAG 2.1 Level AA is equivalent to conforming with clauses 9.1 to 9.4 and the conformance requirements of clause 9.6. So a web page that meets WCAG 2.1 AA meets the web chapter of EN 301 549. Read what WCAG asks for the criteria themselves.

Two things are not the same. EN 301 549 is not WCAG with a European cover: chapters 10 and 11 apply WCAG to non-web documents and to software, including mobile apps, and chapter 12 asks for accessible documentation and support. And it lists the WCAG 2.1 AAA criteria in clause 9.5, but only as information. Level AAA is not required.

Which laws point to it, and who they cover

EN 301 549 is a standard, not a law. Two EU directives give it weight, and public procurement rules add a third route.

• The European Accessibility Act (Directive (EU) 2019/882) covers products placed on the EU market, and services provided to consumers, after 28 June 2025. The services include e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media, and the websites, apps and ticketing of air, bus, rail and waterborne passenger transport. Products include computers and their operating systems, smartphones, e-readers, payment terminals and ATMs. The Act says nothing about EN 301 549 by name. It says a product or service that conforms to a harmonised standard cited in the Official Journal is presumed to meet its requirements, and EN 301 549 is the standard that work has been built on.
• The Web Accessibility Directive (Directive (EU) 2016/2102) covers the websites and mobile apps of public sector bodies. It has applied to all public websites since 23 September 2020 and to public mobile apps since 23 June 2021. Here the link is explicit: Commission Implementing Decision (EU) 2021/1339 names EN 301 549 V3.2.1 as the harmonised standard, so a public body that meets it is presumed to comply.
• Public procurement. The Act makes its accessibility requirements mandatory technical specifications under the EU procurement directives (Directive 2014/24/EU, Article 42). In practice, buyers in the public sector have asked for EN 301 549 conformance for years, and private buyers increasingly copy the question.

The Act has exemptions and transitions worth knowing. Microenterprises providing services (fewer than 10 people and turnover or balance sheet of at most EUR 2 million) are exempt from the service requirements. Service contracts signed before 28 June 2025 may run unchanged until they expire, but no longer than five years. Member States must allow a transition to 28 June 2030 for products already lawfully in use to deliver a service. Each Member State transposes the Act into its own law, so the detail that binds you is national.

Versions, and the move to WCAG 2.2

EN 301 549 has been revised as WCAG moved. V1.1.2 (April 2015) was the first. V2.1.2 (August 2018) took in WCAG 2.1. V3.2.1 (March 2021) revised it again and is the version the Commission cites today.

The next version moves to WCAG 2.2. ETSI published a draft, V4.1.0, dated November 2025, whose web chapter restates the WCAG 2.2 success criteria. Until the Commission cites a new version in the Official Journal, V3.2.1 and WCAG 2.1 remain the legal reference. Check the Official Journal before you write a conformance claim, because the citation is what changes the presumption.

The practical advice is to test against WCAG 2.2 AA now. It contains every WCAG 2.1 AA criterion, so meeting it answers V3.2.1 today and the new version when it lands. Read WCAG 2.2 AA in plain words for what the newer criteria add.

The EU edition of the VPAT, and what buyers read

The VPAT is the free template from the Information Technology Industry Council that vendors fill in to report how a product meets accessibility standards. Filled in, it is an Accessibility Conformance Report. The current template, VPAT 2.5Rev (24 April 2025), comes in four editions. The EU edition reports against EN 301 549, and it incorporates WCAG 2.1 because that is what V3.2.1 includes. The INT edition carries EN 301 549, Section 508 and WCAG together, for vendors selling in several markets.

Buyers rarely stop at the conformance level column. They read the remarks: how many instances were checked, what failed, where, and how the result was reached. A row marked Supports with no explanation is a question waiting to be asked. A row marked Partially Supports with a plain description of the defect and a fix date is what a procurement officer can work with. The EU edition also has tables for the non-web chapters, so a software or app vendor should expect questions beyond WCAG.

What evidence to keep

Both directives are built on the idea that you can show your work. Public sector bodies must publish and keep up to date an accessibility statement that says which parts are not accessible, why, and how a user can report a problem. Under the Act, national authorities check that products and services meet the requirements, and a provider that cannot show how it checked has little to say when asked.

• An accessibility statement, dated, that names the standard and version and lists known gaps.
• Audit records: which pages and states were tested, when, against which criteria, and what was found.
• Decisions: who judged each result that needed a person, what they looked at, and why they decided as they did.
• Remediation history, so a buyer can see that a defect reported last year is closed now.

Where automated testing helps, and where a person is needed

Automated checks are good at the parts of WCAG that have a measurable answer: colour contrast, missing text alternatives, form fields without names, invalid markup, focus that disappears. They can cover every page of a large site and repeat the run after each release, which no team of people can do by hand.

They cannot settle every criterion. Whether an image description is accurate, whether a heading describes its section, whether an error message tells the user what to do, whether a video has an adequate audio description: these need a person who understands the content. An honest report says which results were decided automatically and which a reviewer decided, and it never counts "no problem found" as a pass where the tool could not look.

How Dreven helps

• Dreven checks the pages of your site against WCAG and shows you each result with the evidence behind it, so you can see what failed and where.
• Results that need judgement go to your reviewer, who decides each one and signs. The decision and the reasons are recorded with the evidence.
• The report is drafted in the VPAT 2.5Rev structure for the edition you choose, including the EU edition, with the remarks a buyer expects to read.
• Dreven does not make anyone compliant with the European Accessibility Act or with EN 301 549. It finds problems, keeps the evidence and drafts the report. Your team fixes the problems, and the person who signs makes the claim.

Questions people ask

Is EN 301 549 the same as WCAG?

No. EN 301 549 is a broader standard for ICT products and services. Its web chapter restates the WCAG 2.1 Level A and AA success criteria, so meeting WCAG 2.1 AA meets that chapter. Other chapters cover software, mobile apps, non-web documents, hardware, documentation and support services, which WCAG does not address.

Which version of WCAG does EN 301 549 use?

The version in force, V3.2.1 from March 2021, uses WCAG 2.1 Level A and AA for web content. A draft of the next version, V4.1.0 dated November 2025, moves to WCAG 2.2. Until a new version is cited in the Official Journal of the European Union, V3.2.1 and WCAG 2.1 remain the reference.

Does the European Accessibility Act apply to my business?

It may. The Act covers listed products and services placed on the EU market or provided to consumers after 28 June 2025, including e-commerce, consumer banking, e-books and passenger transport websites and apps. Microenterprises providing services are exempt. Each Member State has written the Act into its own law, so check the national rules or ask an adviser.

What is the difference between the EAA and the Web Accessibility Directive?

The Web Accessibility Directive (2016/2102) covers the websites and mobile apps of public sector bodies and has applied in full since June 2021. The European Accessibility Act (2019/882) covers businesses placing listed products and services on the EU market, from June 2025. Both lean on EN 301 549 as the harmonised standard.

Do I need an EN 301 549 VPAT to sell in the EU?

No law requires a VPAT. Buyers ask for one because it is the format they know. The EU edition of VPAT 2.5Rev reports against EN 301 549, and the INT edition covers EN 301 549, Section 508 and WCAG in one document. Ask the buyer which edition they want before you write it.

Can a tool make my product EAA compliant?

No. A tool can find problems across your pages and keep the evidence, and that is useful. It cannot judge every criterion, it cannot fix your product, and it cannot make the claim for you. People fix the defects, a reviewer decides each result that needs judgement, and the person who signs the report is responsible for what it says.