Digital accessibility: EN 301 549 and WCAG

Short answer: The European Accessibility Act (Directive 2019/882) requires providers of a broad range of digital products and services to meet harmonised accessibility requirements from 28 June 2025. The technical standard that gives those requirements their content is EN 301 549 v3.2.1, which incorporates WCAG 2.1 Level AA in full but also contains additional requirements. Compliance with WCAG 2.1 alone is therefore not sufficient for legal conformity.

What the European Accessibility Act requires

Directive (EU) 2019/882 — the European Accessibility Act (EAA) — had to be transposed into national law by 28 June 2022 and applies from 28 June 2025. The directive covers a wide range of digital products and services: computers and operating systems, smartphones, ATMs and ticketing machines, television equipment, telephony services, access to audiovisual media services, passenger transport services, consumer banking services, and e-commerce. E-books and dedicated reading devices are also included.

Microenterprises (fewer than 10 employees) providing services are exempt. A "disproportionate burden" clause also applies: providers are not required to comply where doing so would fundamentally alter the nature of a product or service or impose an excessive burden. Extended deadlines apply to emergency call services (112) until 28 June 2027 and to existing built infrastructure until 28 June 2030.

The standard: EN 301 549 v3.2.1

The harmonised technical standard for digital accessibility under the EAA is EN 301 549 v3.2.1, published in March 2021 and formally harmonised on 18 August 2021 through the Official Journal of the European Union. The standard was developed by ETSI in cooperation with CEN and CENELEC.

EN 301 549 v3.2.1 incorporates WCAG 2.1 in its entirety, but goes further: the standard also sets requirements for hardware, documents downloaded from the web, and communications services. According to the European Commission, meeting all WCAG 2.1 success criteria does not automatically ensure conformity with EN 301 549 — additional clauses (such as requirements for captions characteristics and speaker identification in video communication) must be addressed separately.

WCAG 2.2 was published on 5 October 2023, but has not yet been incorporated into a harmonised version of EN 301 549. A new version (v4.1.1) incorporating WCAG 2.2 Level AA is expected in 2026, with publication in the Official Journal anticipated for October 2026. Until that publication, WCAG 2.1 remains the operative legal benchmark.

What this means in practice

Organisations offering digital products or services within the EAA's scope must carry out a conformity assessment against EN 301 549 v3.2.1 — not solely against WCAG. WCAG audits provide a solid starting point, but a full EN 301 549 assessment covers requirements beyond web content. Newly released offerings are subject to the obligation immediately; existing services were required to comply by 28 June 2025.