Glossary · Accessibility term
EN 301 549
EN 301 549 is the European standard for accessible information and communication technology, written first for public procurement and now the document European accessibility law reaches for when it needs a technical answer. For a website the operative part is clause 9. It adopts WCAG 2.1 at Levels A and AA outright rather than restating them, and adds WCAG's five conformance requirements in a clause of its own, so most of what the standard asks of a site is WCAG AA under a different number. The rest of it covers ground WCAG never touches, including hardware, software, non-web documents, real-time text inside a voice call, and one clause about your own documentation and support channels. Version is the thing to watch here. The published version in force is V3.2.1, which is where the WCAG 2.1 figure comes from. A successor moving to WCAG 2.2 has been drafted and is not yet cited in the Official Journal. So it is not the legal yardstick anywhere yet.
In practice
Nobody hands you EN 301 549 as a rule. You end up measured against it, because a law sets functional requirements and then grants a presumption of conformity to a harmonised standard covering the thing you built. This standard has that status under one law and not the other. Its reference is published in the Official Journal under the public-sector Web Accessibility Directive, so a public body meeting it is presumed to comply. Nothing is yet cited that way under the European Accessibility Act, and a presumption never travels from one directive to another. So a private supplier using this standard is using the best technical answer available rather than collecting a legal presumption.
Clause 9 is the web clause and it is the reason this is manageable. It adopts WCAG 2.1 at Levels A and AA criterion by criterion rather than rewriting them, and then clause 9.6 adds all five WCAG conformance requirements on top, so full pages, complete processes, accessibility support and non-interference all come with it. A site conforming to WCAG 2.2 clears the criteria, because 2.2 keeps the same conformance model and content meeting 2.2 meets 2.1 as well. One wrinkle survives that. WCAG 2.2 removed Parsing, so a clause 9 report against this version still wants a row for it, and the answer in that row is that Parsing counts as always satisfied for content using HTML or XML. Having tested is not the same as having passed, and clause 9.6 is where a criterion-by-criterion report tends to fall short.
Clause 12 is the one suppliers miss, because it is not about the product at all. It covers your user documentation, your help content and your support services, the call centre and the chat window included, and it asks that those be accessible themselves and offered in accessible formats. Clause 4 is the other one worth knowing, and knowing what it is not. It sets functional performance statements covering use without vision, without hearing, with limited manipulation and so on. The standard's own annex says clause 4 is informative and contains nothing that requires testing, so it describes the outcomes the testable clauses are aiming at rather than acting as a catch-all requirement.
Why it matters
Meeting WCAG 2.1 AA buys you clause 9 and nothing beyond it, which is how a supplier passes a WCAG audit and then fails a procurement check on its own help pages. The version question is the other place to be careful. Until a newer version is cited in the Official Journal, the harmonised standard stays at V3.2.1. The WCAG level behind it is 2.1 Level A and AA. Anybody quoting WCAG 2.2 as the current European legal bar is quoting a future one. Check the version before you quote the level, and check which directive somebody means before you quote the presumption.
Which VPAT edition a European buyer expects
There are four editions and the naming trips people up. The EU edition is the one built on EN 301 549, and it is what a European buyer is asking for. The INT edition folds in Section 508 and WCAG as well. Fill that one in if you sell into the United States too. Section 508 still names WCAG 2.0, so otherwise you are answering two different WCAG versions in two separate documents.
Where this shows up on the site
Related terms
- European Accessibility ActThe European Accessibility Act is the EU law that has required certain consumer products and services to be accessible since 28 June 2025, and the word to hold onto is certain.
- WCAGWCAG is the international standard for web accessibility, published by the W3C.
- VPATA VPAT is the blank form vendors fill in to report how their product measures against accessibility standards, one row per requirement, using one of five verdicts.
- ConformanceConformance means satisfying all the requirements of a standard, and WCAG has five of them rather than one.
- Section 508Section 508 is the US law requiring federal departments and agencies, plus the Postal Service, to make their digital products accessible.
Knowing the word is the easy part.
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