What Is EN 301 549?
EN 301 549 is the European harmonized standard for ICT accessibility, published by ETSI. It defines the functional accessibility requirements that digital products and services must meet to comply with European accessibility law, including the European Accessibility Act (Regulation EU 2019/882). For US companies selling software, websites, or hardware into European markets, EN 301 549 is the technical benchmark against which EAA compliance is measured.
The Relationship Between EN 301 549 and WCAG 2.1
EN 301 549 version 3.2.1 incorporates WCAG 2.1 Level AA in its entirety within Chapter 9 (Web) and Chapter 10 (Non-web documents). Every WCAG 2.1 AA success criterion is therefore a legal requirement under the EAA. However, EN 301 549 goes further, adding requirements for closed functionality, real-time text, two-way voice communication, and hardware.
Full Scope: What EN 301 549 Covers
- Chapter 9 — Web content and web-based services (incorporates WCAG 2.1 AA)
- Chapter 10 — Non-web documents (PDFs, Word files, spreadsheets, presentations)
- Chapter 11 — Native mobile apps (iOS, Android) and desktop software
- Chapter 12 — Two-way voice communication (VoIP, video calling, conferencing tools)
- Chapter 8 — Hardware (ATMs, kiosks, ticketing machines, payment terminals)
- Chapter 6 — ICT with closed functionality
How to Test Against EN 301 549
- Run automated scans against WCAG 2.1 AA using Axe-core, Lighthouse, or IBM Equal Access Checker
- Conduct manual keyboard-only navigation testing across all user flows
- Test with screen readers: NVDA and JAWS on Windows, VoiceOver on macOS and iOS, TalkBack on Android
- Audit non-web documents (PDFs, DOCX) using Adobe Acrobat Accessibility Checker and PAC 2024
- Evaluate mobile apps against Chapter 11 requirements using platform accessibility inspectors
- Document findings in a VPAT or EU Declaration of Conformity
Getting Started With EN 301 549 Compliance
The most effective first step for US companies is a gap analysis mapping existing WCAG 2.1 AA conformance against the full EN 301 549 requirement set. BuildWithAccess provides structured EN 301 549 audits producing chapter-by-chapter conformance matrices, remediation backlogs prioritized by legal risk, and draft EU Declarations of Conformity.
Dr. Lisa Chen
Director of Accessibility
A certified accessibility consultant at BuildWithAccess helping organizations achieve WCAG compliance and build more inclusive digital experiences.
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