Accessibility law · Europe

European Union EN 301 549 V3.2.1 → WCAG 2.1 AA

In the European Union, the standard to meet is EN 301 549 V3.2.1 → WCAG 2.1 AA. It binds public sector bodies in all 27 member states and, since 28 June 2025, businesses that sell the consumer products and services listed in the European Accessibility Act. This page was reviewed against primary sources on 30 September 2026.

Standard
EN 301 549 V3.2.1 → WCAG 2.1 AA
Private sector
Partly
Accessibility statement
Required
Next deadline
28 Jun 2027
Reviewed
30 September 2026
The 50 criteria All jurisdictions Checklist

Scope

Who it applies to

Two directives set the rules, and each member state turns them into national law. Public sector websites and apps must meet EN 301 549 (clause 9 is WCAG 2.1 Level AA) and publish an accessibility statement with a feedback route. Since 28 June 2025 the European Accessibility Act also covers e-commerce, consumer banking, e-books, transport ticketing, telecoms and devices such as ATMs and ticket machines. Penalties and enforcers are national, not EU-level.

  • Public sector

    Websites and mobile apps of the State, regional and local authorities and bodies governed by public law (Directive 2016/2102). Public service broadcasters are excluded, and member states may exclude schools, kindergartens and nurseries except for essential online administrative functions.

  • Private sector

    Partly

    Economic operators that place listed products on the EU market after 28 June 2025 (consumer computers and operating systems, payment terminals, ATMs, ticketing and check-in machines, smartphones, TV equipment, e-readers) or provide listed services to consumers (e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media, elements of passenger transport). Microenterprises that provide services are exempt.

Coverage

What it covers

Websites are only part of it. Each tile says whether these rules reach that kind of product, with the detail.

  • Websites

    Covered

    Public sector sites under the WAD; the websites of e-commerce, banking, transport and other listed services under the EAA.

  • Mobile apps

    Covered

    Public sector mobile apps since 23 June 2021; mobile services of the listed private services since 28 June 2025.

  • Documents

    Partly

    Office files published before 23 Sep 2018 (WAD) or before 28 Jun 2025 (EAA) are exempt, unless a WAD body needs them for an active administrative process.

  • Software

    Partly

    The EAA covers consumer operating systems, e-book software and the software in listed products; the WAD does not cover general software.

  • Kiosks and terminals

    Covered

    The EAA covers payment terminals, ATMs, ticketing and check-in machines and interactive information terminals.

  • Public procurement

    Partly

    EAA Annex I requirements count as mandatory accessibility requirements in public procurement under Directives 2014/24/EU and 2014/25/EU.

Timeline

Deadlines

Next: 28 Jun 2027. Latest date member states may allow for making the answering of 112 emergency calls accessible.

Dates move, so check the linked source before you plan around one.

  1. 23 Sep 2019 In force

    Public sector websites published on or after 23 September 2018 must comply.

    Source

  2. 23 Sep 2020 In force

    All other public sector websites must comply.

    Source

  3. 23 Jun 2021 In force

    Public sector mobile apps must comply.

    Source

  4. 28 Jun 2022 In force

    Deadline for member states to adopt and publish their EAA laws.

    Source

  5. 28 Jun 2025 In force

    The European Accessibility Act applies to products placed on the market and services provided from this date.

    Source

  6. 24 Aug 2026 In force

    EN 301 549 V4.1.1, aligned with WCAG 2.2, is adopted. It gives a presumption of conformity only once cited in the Official Journal, which had not happened by this review.

    Source

  7. 28 Jun 2027 Upcoming

    Latest date member states may allow for making the answering of 112 emergency calls accessible.

    Source

  8. 28 Jun 2030 Upcoming

    Transition ends for services still run on products used before 28 June 2025, and for service contracts agreed before that date. Self-service terminals may stay in use to the end of their economic life, up to 20 years, if the member state allows it.

    Source

Instruments

The law in the European Union

5 laws, rules and rulings, oldest first. Each links to its primary source.

Every fact points at a primary source. Dates move, and several moved in 2025 and 2026, so check the source before you rely on one.

  1. 2016

    Web Accessibility Directive

    Directive (EU) 2016/2102

    Public sector websites and mobile apps must be perceivable, operable, understandable and robust, with a published accessibility statement and a working feedback route. Member states monitor and report every three years.

    Primary source

  2. Oct 2018

    Model accessibility statement and monitoring methodology

    Implementing Decisions (EU) 2018/1523 and 2018/1524

    2018/1523 fixes the model accessibility statement and its mandatory content. 2018/1524 sets how member states sample and test public sector sites and apps (in-depth and simplified monitoring) and how they report.

    Primary source

  3. Aug 2021

    EN 301 549 V3.2.1

    harmonised standard under the WAD, cited by Implementing Decision (EU) 2021/1339

    The standard public sector sites are measured against; meeting it gives a presumption of conformity with the WAD. Clauses 9 to 11 follow WCAG 2.1 Level AA.

    Primary source

  4. Jun 2025 Latest

    European Accessibility Act

    Directive (EU) 2019/882

    Reaches the private sector: listed consumer products and services must meet the Annex I requirements from 28 June 2025. Service microenterprises are exempt. Enforcement and penalties are national.

    Primary source

  5. Sep 2026

    EN 301 549 V4.1.1

    ETSI, CEN and CENELEC, adopted 24 August 2026; not yet cited in the Official Journal

    The revision written for both directives. Clauses 9 to 11 move to WCAG 2.2, and new Annex ZB and clause A.2 map it to the EAA. Until it is cited in the Official Journal, V3.2.1 remains the cited reference.

    Primary source

Enforcement

Enforcement and penalties

  • Who enforces

    No EU-level enforcer. Each member state designates market surveillance authorities for products and authorities that check the compliance of services (EAA Articles 19 and 23), plus a monitoring body and an enforcement procedure for public sector sites (WAD Articles 8 and 9).

  • How

    Public sector sites are monitored on the Commission's methodology (Implementing Decision 2018/1524), with in-depth and simplified checks and a national report every three years. Under the EAA, authorities check services, follow up complaints and verify corrective action; for products the market surveillance rules of Regulation 765/2008 apply.

  • Penalties

    Set nationally. The EAA requires penalties that are effective, proportionate and dissuasive, that come with remedial action, and that reflect the seriousness of the breach, the number of non-compliant units or services and the number of people affected. The WAD sets no penalty.

  • Individuals

    Under the EAA, consumers must be able to go to a court or a competent administrative body, and associations with a legitimate interest may act on their behalf or in support. Under the WAD, anyone can use the statement's feedback mechanism and then the national enforcement procedure, such as an ombudsman.

Accessibility statement

A statement is required

Required

Public sector bodies must publish a detailed accessibility statement for each website and app, using the Commission's model (Implementing Decision 2018/1523): compliance status (fully, partially or not compliant), the content that is not accessible and why, a feedback mechanism, and a link to the national enforcement procedure. The Commission encourages a review at least once a year. Under the EAA there is no statement as such: service providers must explain how the service meets the requirements in their general terms and conditions or an equivalent document (Annex V), in accessible formats.

Exemptions

What is exempt

Exemptions are narrow and usually have to be claimed and explained, not assumed.

  • Disproportionate burden, assessed and documented by the body or operator (WAD Article 5; EAA Article 14, reassessed at least every five years for services).
  • Fundamental alteration of the basic nature of a product or service (EAA Article 14).
  • Microenterprises providing services: fewer than 10 staff and turnover or balance sheet of no more than €2 million (EAA Article 4(5)).
  • Pre-recorded time-based media and office files published before the cut-off dates (23 Sep 2020 and 23 Sep 2018 under the WAD; 28 Jun 2025 under the EAA).
  • Online maps, if essential navigation information is given in an accessible way.
  • Third-party content that the body or operator neither funds, develops nor controls.
  • Archives that are not updated or edited after 23 Sep 2019 (WAD) or 28 Jun 2025 (EAA).
  • Live time-based media, heritage collection reproductions that cannot be made accessible, and older intranet and extranet content until a substantial revision (WAD only).

The standard

What WCAG 2.1 Level AA asks for

50 success criteria: 30 at Level A and 20 at Level AA. 4.1.1 Parsing counts in this version, but WCAG 2.2 removed it as obsolete, so it has no page here.

1. Perceivable

2. Operable

3. Understandable

4. Robust

Beyond the law

6 Level A and AA criteria in WCAG 2.2 that these rules do not require yet. Meeting them now costs little and is where the rules are heading.

Meeting it

Where to start

The standard named here is WCAG 2.1 Level AA.

  1. Audit your pages against WCAG 2.1 Level AA: 50 success criteria at Level A and AA.
  2. Check text and control contrast in the Contrast Checker.
  3. Run the URL Analyzer for the problems a machine can find, then test with a keyboard and a screen reader.
  4. Publish an accessibility statement that says what does not meet the standard yet, and how to report a problem.
  5. If you sell to the public sector, document conformance in an accessibility conformance report, such as a VPAT or an EN 301 549 statement.
  6. Work through the Accessibility Checklist and keep a record of what you tested.

This is a summary to orient you, not legal advice. For a decision that matters, read the primary sources and ask a lawyer who practices there.

Questions

Common questions

  • Does the EU law apply directly to my company?

    Not directly. Both are directives, so you are bound by your member state's law that transposes them. That law names the authority, sets the penalties and may add rules, as France, Germany and Italy do.

  • Is my online shop covered by the European Accessibility Act?

    Yes if it sells to consumers at a distance through a website or app, unless you are a microenterprise (fewer than 10 staff and no more than €2 million turnover or balance sheet). The Act defines e-commerce services as services provided at a distance, by electronic means, at a consumer's request, with a view to concluding a consumer contract.

  • Which WCAG version do I need to meet?

    In practice WCAG 2.1 Level AA, through EN 301 549 V3.2.1. EN 301 549 V4.1.1, adopted in August 2026, moves to WCAG 2.2, but it only gives a presumption of conformity once the Commission cites it in the Official Journal. The Commission notes there are no breaking changes from WCAG 2.1 to 2.2, so building to 2.2 AA now is a safe choice.

  • Can we keep an old ATM or ticket machine?

    Self-service terminals lawfully used before 28 June 2025 may stay in use until the end of their economic life, but no longer than 20 years after they entered use, where the member state allows it. France and Germany cap this at 15 years.

  • Do we need an accessibility statement as a private company?

    Not under EU law as such. The EAA requires service providers to publish, in their terms and conditions or an equivalent document, how the service meets the accessibility requirements. Some national laws, such as France's, add a statement duty for large companies.

Sources

Sources

Every fact on this page comes from one of these; the few secondary sources are marked. Reviewed 30 September 2026.

Elsewhere

Also in Europe

Other regions