What EN 301 549 asks of a website beyond WCAG
Clause 9 of EN 301 549 V3.2.1 is WCAG 2.1 A and AA; Table A.1 adds 42 rows from clauses 5, 6, 7, 11 and 12, each applying when its condition holds.
In short: Clause 9 of EN 301 549 V3.2.1 is WCAG 2.1 Level A and AA, so a site that meets WCAG 2.1 AA meets clause 9. Table A.1, the list the EU's Web Accessibility Directive relies on, also applies clauses on video players, calls, user settings, authoring tools, documentation and support, each when its "Where…" condition holds.
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When you need this
A web team is rebuilding the website of a public museum in an EU member state. The contract says the site must conform to EN 301 549 V3.2.1. The team's audit of 12 pages against WCAG 2.1 Level AA has no open failures, and the project lead wants to sign the site off on that report.
Besides its pages, the site has its own video player for 4 exhibition films, a text size switch in the header, an events editor that curators use to publish event pages, an accessibility statement, and a phone number that is the only way to book a group visit. The question is whether the WCAG report covers all of that.
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How the standard is laid out
EN 301 549 is written for any ICT, not only websites: phones, kiosks, documents, software and support services too. A website meets only the parts whose conditions it sets off, but those parts are spread across the whole standard.
| Part | What it holds | Status |
|---|---|---|
| Clause 4 | 11 functional performance statements: what ICT lets people do without vision, with limited hearing and so on, plus privacy | Informative; Annex C has no test for it |
| Clause 5 | Generic requirements, such as 5.2 activation of accessibility features and 5.3 biometrics | Requirements |
| Clause 6 | ICT with two-way voice communication, real-time text (RTT) included | Requirements |
| Clause 7 | ICT with video: caption and audio description technology, and their controls | Requirements |
| Clause 8 | Hardware | Requirements |
| Clause 9 | Web pages: WCAG 2.1 | Requirements |
| Clause 10 | Non-web documents | Requirements |
| Clause 11 | Software, with 11.7 user preferences and 11.8 authoring tools | Requirements |
| Clause 12 | Documentation and support services | Requirements |
| Clause 13 | Relay and emergency service access | Requirements |
| Clause 14 | Conformance: what meeting the standard means | Defines conformance |
| Annex A | The clauses that serve the Web Accessibility Directive: Table A.1 for web pages and documents, Table A.2 for mobile apps | Informative |
| Annex B | Which requirements support which functional performance statement | Informative |
| Annex C | The test for each requirement | Normative |
Clauses 10 and 11 apply WCAG to documents and software, and the standard says they are intended to harmonise with WCAG2ICT, the W3C note on applying WCAG to non-web ICT. The current WCAG2ICT is the Group Note of 11 December 2025, which covers WCAG 2.0, 2.1 and 2.2. It is informative and says itself that it is not a standard, so nothing can conform to it. Annex E is the standard's own guide for first-time readers.
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Clause 9 is WCAG 2.1 Level A and AA
- 9.1 to 9.4: one clause for each WCAG 2.1 Level A and AA success criterion, numbered after it, so 9.1.1.1 is 1.1.1. Each reads the same way: "Where ICT is a web page, it shall satisfy WCAG 2.1 Success Criterion 1.1.1 Non-text content."
- 9.5: the 28 Level AAA criteria, in Table 9.1. Authors are "encouraged to consider" them; the clause has no "shall", so nothing in it is required.
- 9.6: the five WCAG 2.1 conformance requirements at Level AA, required for every web page. What they ask is on what it takes for a page to conform to WCAG.
- 9.4.1.1 Parsing: still required, because WCAG 2.1 still has 4.1.1. WCAG 2.2 removed it, and V4.1.1 leaves 9.4.1.1 void.
Clause 9.0, which is informative, says meeting WCAG 2.1 Level AA "is equivalent to conforming with all of clauses 9.1 to 9.4 and the conformance requirements of clause 9.6". For clause 9, then, a sound WCAG 2.1 AA result is the whole answer. Table A.1 lists 49 of the 50 criteria. It leaves out 9.1.2.4 Captions (live), because the Web Accessibility Directive does not apply to live time-based media (its Article 1(4)(c)).
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The rows of Table A.1 that WCAG doesn't cover
Table A.1 has 137 rows. 50 are clause 9 (49 criteria and 9.6), and 45 are clause 10, for documents downloadable from a web page. The other 42 come from clauses 5, 6, 7, 11 and 12. Counted by clause rather than by row, they are 39 clauses, because 6.2.3 Interoperability takes 4 rows, one for each of its items a) to d). Each row has a condition, and the row applies to a site only when the condition is true.
| Clauses (rows) | Applies where | Example |
|---|---|---|
| 5.2 Activation of accessibility features (1) | The web content has documented accessibility features | Accessibility settings that need the feature they turn on |
| 5.3 Biometrics, 5.4 Preservation of accessibility information during conversion (2) | The web content uses biological characteristics; converts information or communication | None yet |
| 6.1 to 6.5.6 (19) | The web pages provide two-way voice communication, with RTT or video | None yet |
| 7.1.1 to 7.3 (9) | The web content displays video with synchronized audio or displays captions, or the pages transmit, convert or record such video; 7.3 where pages primarily display video with audio | Video players with no captions button in the control bar, videos a keyboard can't play, captions stuck in one style, or lost when video is converted |
| 11.7 User preferences (1) | Every web page: the table marks it U, unconditional | None yet |
| 11.8.1 to 11.8.5 (5) | The web content is an authoring tool | Image uploads that never ask for alt text |
| 12.1.1, 12.1.2, 12.2.2 to 12.2.4 (5) | Every web page: the table marks them U | Accessibility statements that are missing or say nothing, support that can only be reached by phone |
Clause 7 is about the player, not the film. Its note to 7.1.1 says so: 7.1.1 is the player's ability to show captions, while 9.1.2.2 is the captions the video has. 11.7 asks a user interface to follow the platform's settings for units of measurement, colour, contrast, font type, font size and focus cursor, unless the user overrides them, and its note says that for web content the platform is the user agent. ATAG and the rest of 11.8 are on what a CMS or editor owes the people who write in it.
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How a clause decides whether it applies
Every clause except those in clause 12 is self-scoping: it opens with a condition, Where ICT <pre condition>, and the requirement after it applies only when the condition is true. Clause 14 lists the four results a test in Annex C can give:
- Pass: the condition is true and the test's checks are true.
- Fail: the condition is true and a check is false.
- Not applicable: the condition is false. A site with no video gets this for all 9 clause 7 rows.
- Not testable: only "in exceptional circumstances".
Each test in Annex C names its type of assessment (inspection, testing, measurement or a combination), its pre-conditions, its procedure and its result. C.7.3 has one pre-condition, "The ICT primarily display materials containing video with associated audio content", and one check: that the controls for subtitling and audio description are "at the same level of interaction as the primary media controls". Where a clause doesn't open with "Where ICT…" itself, as 11.8 doesn't, Table A.1's condition column gives the condition ("Where web content is an authoring tool").
In V3.2.1, clause 4 states needs rather than tests: Annex C says it "does not contain requirements that require testing". The functional performance statements are the reason for every requirement, and Annex B says which requirement supports which statement. It marks each relationship P, primary, or S, secondary, where "some users may use the feature in specific situations". The row for 7.3 is P for usage without vision, with limited vision, without hearing and with limited hearing, and S for limited cognition. The groups themselves are described on who is affected. The eleventh statement, 4.2.11, is privacy: "Where ICT provides features for accessibility, the ICT maintains the privacy of users of these features at the same level as other users." Its note gives three examples: personal headsets for private listening, not speaking masked characters aloud, and user control of legal, financial and personal data.
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Who relies on it, and which edition
| Who | Law or use | What EN 301 549 does for it |
|---|---|---|
| Public sector bodies' websites and apps in the EU | Directive (EU) 2016/2102, the Web Accessibility Directive: new websites from 23 September 2019, all websites from 23 September 2020, apps from 23 June 2021 (Article 12) | Content that meets the clauses in Tables A.1 and A.2 has a presumption of conformity with the Directive's Article 4: perceivable, operable, understandable and robust |
| Services and products for consumers: e-commerce, consumer banking, e-books, passenger transport, electronic communications and more | Directive (EU) 2019/882, the European Accessibility Act, applied from 28 June 2025 (Article 31); microenterprises providing services are exempt from the service requirements (Article 4(5)) | Article 15 gives a presumption of conformity to harmonised standards whose references are published in the Official Journal; V4.1.1 maps the Act's requirements in its Annex ZB |
| Public buyers | Procurement: the standard is written "in a form that is suitable for use in public procurement within Europe"; the Act's Annex I counts as mandatory accessibility requirements under the public procurement Directive 2014/24/EU (Article 24) | The clauses a tender names, and the Annex C tests to check them |
EN 301 549 is a harmonised standard, and a harmonised standard gives a presumption of conformity only from the day its reference is published in the Official Journal of the European Union. The editions, as of this page's date:
- V3.2.1 (2021-03): WCAG 2.1. Commission Implementing Decision (EU) 2021/1339 of 11 August 2021 published its reference under the Web Accessibility Directive, in place of V2.1.2.
- V4.1.1 (2026-09): published by ETSI in September 2026 and prepared under the Commission's request for the European Accessibility Act. Its foreword lists the changes: clauses 9, 10 and 11 align with WCAG 2.2, and Annex A becomes A.1 and A.2, with Annex ZA for the Web Accessibility Directive and Annex ZB for the Act. Inside, authoring tools move from 11.8 to 5.10, a new 9.7 covers user preferences for web pages, and clause 4 becomes "functional performance criteria", worded with "shall" and tested in C.4. Its own foreword says the presumption comes "Once the present document is cited in the Official Journal of the European Union".
To check for a newer edition, look at ETSI's list of published versions (etsi.org/deliver, under 301549); for the Official Journal references, the Commission's harmonised standards pages and EUR-Lex.
Outside Europe, Australia adopts the standard as AS EN 301 549:2024, which Standards Australia says "identically adopts EN 301 549:2021", that is, V3.2.1. A vendor reports against EN 301 549 in the EU edition of the VPAT, VPAT 2.5Rev EU (April 2025) as this page was written; how to read one is on reading a vendor's VPAT before you buy, and what to ask next.
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Worked example
The museum's site, row by row through Table A.1 for the parts the WCAG report didn't look at:
| Rows | Applies? | Result |
|---|---|---|
| 9.1 to 9.4, 9.6 | Yes, on every page | Pass on the 12 pages tested, from the WCAG 2.1 AA report |
| 5.2 | Yes: the statement documents the text size switch | Fail: the switch is set in 11 px grey type, so someone who needs larger text can't read it to turn it on |
| 5.3, 5.4 | No: no biometric sign-in, and nothing is converted | Not applicable |
| Clause 6 (19 rows) | No: the site makes no calls | Not applicable |
| 7.1.1, 7.1.2, 7.1.4, 7.1.5, 7.2.1, 7.2.2 | Yes: the player shows films with sound | 7.1.4 fails: there is no way to change the captions' size or colours |
| 7.1.3, 7.2.3 | No: the films are played as uploaded, not converted | Not applicable |
| 7.3 | Yes: the films page primarily displays video | Fail: volume takes 1 press, captions take 3, through a settings menu |
| 11.7 | Yes | Pass: text follows the browser's font size, and no style overrides its colours |
| 11.8.1 to 11.8.5 | Yes: curators publish event pages with the events editor | 11.8.2 fails: the image upload never asks for alt text |
| 12.1.1, 12.1.2 | Yes | Pass: the statement lists the text size switch and how to use it, on an accessible web page |
| 12.2.2 to 12.2.4 | Yes | 12.2.3 fails: group bookings can only be made by phone |
Result: the WCAG report covers the 50 clause 9 rows. Of the 42 rows outside clauses 9 and 10, 5 fail here: 5.2, 7.1.4, 7.3, 11.8.2 and 12.2.3. No WCAG criterion checks any of them, so the site can't be signed off as conforming to EN 301 549 on the WCAG report alone. Annex B shows whom the failures reach: 7.3 is primary for 4 groups, people without vision, with limited vision, without hearing and with limited hearing; 12.2.3 is primary for people without hearing, with limited hearing and with no or limited vocal capability. The site offers no downloadable documents, so the 45 clause 10 rows are not applicable. The statement itself, with its feedback mechanism, is checked against the Directive's Article 7, not against the standard.
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Common mistakes
- Treating a WCAG 2.1 AA report as EN 301 549 conformance. It settles clause 9 only. Table A.1's other rows apply whenever their condition is true, and the clause 12 rows always do. Check each row's condition, as in the worked example.
- Testing clause 4 as a checklist. In V3.2.1, clause 4 is informative and Annex C has no test for it. Its statements explain the requirements and help compare proposals (Annex E.4.2); the requirements are in clauses 5 to 13. Who each failure reaches is on who is affected.
- Reading 9.5 as required. It lists the AAA criteria with no "shall". A contract can still name some of them; the standard doesn't.
- Testing a player's captions button under 9.1.2.2. 9.1.2.2 is whether the video has captions; where the button sits is 7.3, and the guide is video players with no captions button in the control bar.
- Claiming a presumption of conformity from V4.1.1 before its reference is published in the Official Journal. The presumption comes from the publication, not from ETSI's release.
- Taking 12.1.1 for the Directive's accessibility statement. 12.1.1 asks documentation to list the accessibility features and explain how to use them, and its note names the statement as one place to do it. The statement the Directive requires, with the parts that aren't accessible, a feedback mechanism and a link to the enforcement procedure, is its Article 7, and Annex E.5 says the Directive's requirements on monitoring and accessibility statements "are not covered in EN 301 549". What a statement says is in accessibility statements that are missing or say nothing.
- Carrying the live captions exception from one law to the other. Table A.1 leaves out 9.1.2.4 because the Web Accessibility Directive excludes live time-based media (Article 1(4)(c)). The European Accessibility Act's list of excluded content (Article 2(4)) doesn't name live media.
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What the standard says
- Conformance (clause 14, required): "Conformance to the present document is achieved by meeting all the applicable requirements, these are clauses containing the word "shall". Those clauses containing the word "should" are recommendations and are not required for conformance." It adds: "The present document does not prioritize requirements." What to fix first is on which findings to fix first, and when to rebuild instead.
- Clause 9.6 (required): "Where ICT is a web page, it shall satisfy all the following five WCAG 2.1 conformance requirements at Level AA."
- Clause 9.0 (informative): WCAG 2.1 Level AA "is equivalent to conforming with all of clauses 9.1 to 9.4 and the conformance requirements of clause 9.6".
- Clause 7.3 (required): "user controls to activate subtitling and audio description shall be provided to the user at the same level of interaction (i.e. the number of steps to complete the task) as the primary media controls."
- Clause 12.2.3 (required): "ICT support services shall accommodate the communication needs of individuals with disabilities either directly or through a referral point." The note to its test, C.12.2.3, says "the provision of any level of support for the communication needs of individuals with disabilities constitutes a pass".
- Annex A (informative): conformance with the clauses in Tables A.1 and A.2 "confers, within the limits of the scope of the present document, a presumption of conformity" with the Directive, and "stays valid only as long as a reference to the present document is maintained in the list published in the Official Journal".
- Web Accessibility Directive, Article 6(1) (law): content that meets harmonised standards whose references are published in the Official Journal "shall be presumed to be in conformity with the accessibility requirements set out in Article 4".
How Section 508 differs:
- Its web content requirement is WCAG 2.0 Level A and AA (E205.4), where EN 301 549 V3.2.1 asks for WCAG 2.1.
- Its functional performance criteria (302.1 to 302.9) are 9 requirements worded with "shall", with no group for photosensitive seizures and none for privacy. EN 301 549 V3.2.1 has 11 statements, both included, and doesn't test them.
- Its caption control requirement (503.4.1) asks for the same menu level as volume or program selection, where EN 301 549 7.3 counts the number of steps.
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Limits
This page doesn't settle whether a site falls under the Web Accessibility Directive or the European Accessibility Act, or whether a disproportionate burden applies (Article 5 of the Directive, Article 14 of the Act). Those are for the client and a lawyer, under the national law that carries each Directive. The Directive is minimum harmonisation (Article 2), so a member state can ask for more than Table A.1. Which edition a contract names is the contract's choice: one written before September 2026 may still name V3.2.1 after V4.1.1's reference is published. The standard doesn't say how to sample a site (clause 14, note 2); that is on testing a whole site against WCAG, and standing behind the result. Whether a row's condition is true, and how far a "Not testable" result reaches, is the tester's call, written down with the reason.
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Terms
- functional performance statements
- Clause 4's descriptions of what ICT lets people do whatever their abilities: without vision, with limited hearing and so on, eleven in all, privacy included.
- self-scoping
- A requirement that opens with its own condition, "Where ICT…"; when the condition is false, the requirement is not applicable.
- harmonised standard
- A European standard drafted at the Commission's request for a Directive; once its reference is published in the Official Journal, meeting it gives a presumption of conformity.
- presumption of conformity
- Content that meets the clauses a Directive's table lists is presumed to meet the Directive's accessibility requirements, for as long as the standard's reference stays in the Official Journal.
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Sources and guides
- Required EN 301 549 V3.2.1 (2021-03): Clauses 5 to 14 and Annex C: the requirements and their tests (opens in a new tab)
- Advice EN 301 549 V3.2.1 (2021-03): Clause 4, Annexes A, B and E (informative) (opens in a new tab)
- Advice EN 301 549 V4.1.1 (2026-09): Foreword: the changes since V3.2.1 (opens in a new tab)
- Required Directive (EU) 2016/2102 (Web Accessibility Directive): Articles 1, 4, 6, 7 and 12 (opens in a new tab)
- Required Directive (EU) 2019/882 (European Accessibility Act): Articles 2, 4, 14, 15, 24 and 31 (opens in a new tab)
- Required Commission Implementing Decision (EU) 2021/1339: Annex: the reference of EN 301 549 V3.2.1 (opens in a new tab)
- Advice WCAG2ICT (W3C Group Note, 11 December 2025): Interpretation for non-web documents and software (opens in a new tab)
- Advice ITI VPAT 2.5Rev EU: The EN 301 549 edition of the template (opens in a new tab)
Guides that show it
- Video players with no captions button in the control bar A shop's own video player puts play and volume in its control bar, but captions and audio description three steps deep in a settings menu.
- Videos a keyboard can't play, or with no captions button A product video's play button takes only clicks and says nothing, or the site's own player has no button for the video's captions and described version.
- Captions stuck in one style, or lost when video is converted A shop's video player draws captions small and white with no settings to change them, and its streaming encoder drops the captions and audio description.
- Accessibility settings that need the feature they turn on No standard requires a high contrast mode or a pause switch, but one a site offers must be reachable without it, not set in faint grey or after the motion.
- Image uploads that never ask for alt text A marketplace's listing form uploads each photo and publishes it with its file name as the alt text, without ever asking the seller what the photo shows.
- Accessibility statements that are missing or say nothing A shop has no page saying what works with assistive technology, what is known not to, or whom to tell, or has one that only claims to meet WCAG.
- Support that can only be reached by phone A shop's order page says that the only way to change a delivery is to call, so customers who can't hear or speak on the phone have no way to ask.
This page explains a practice, with recreated examples. It is not legal advice, and it is not a finding about a named client.