EU Web Accessibility Directive and EN 301 549

7 min read · BoK 3E· p. 61–62

Learning objectives (3)

List the four main requirements the Web Accessibility Directive imposes on public sector bodies
Explain the presumption of conformity that EN 301 549 provides under the WAD
Distinguish EN 301 549's scope from the WCAG-only approach of Section 508

Why it matters

The Web Accessibility Directive (WAD) is the primary EU law requiring public sector websites and apps to be accessible. EN 301 549 is the technical standard that operationalizes the WAD’s requirements. Together, they create a comprehensive ICT accessibility framework for EU public services. CPACC candidates must know what the WAD requires, what the standard covers, and how they interrelate. (BoK p. 61)

The Web Accessibility Directive (Directive 2016/2102)

The Web Accessibility Directive entered into force in December 2016. It applies to public sector bodies in all EU member states: national, regional, and local government entities, and related public-body organizations. Private sector entities are not covered by the WAD (they are addressed by the EAA, covered in the next lesson). (BoK p. 61)

The WAD imposes four main requirements on public sector bodies:

Conformant websites and mobile apps: Websites and apps must meet the accessibility requirements in EN 301 549 (the harmonized standard). (BoK p. 62)
Accessibility statement: Each site and app must include a publicly accessible accessibility statement declaring its conformance status, listing known accessibility barriers, and providing contact details. (BoK p. 62)
Feedback mechanism: A mechanism must be provided so that users can report accessibility barriers and request information in an accessible format. (BoK p. 62)
Monitoring and reporting: Member states must monitor public sector bodies’ conformance and report their findings to the European Commission on a regular basis. (BoK p. 62)

EN 301 549 and the presumption of conformity

EN 301 549 is a European standard published by ETSI, CEN, and CENELEC. It specifies accessibility requirements for ICT products and services — not just web content but also software, hardware, documentation, and support services. (BoK p. 62)

When the European Commission publishes EN 301 549’s reference in the Official Journal of the EU as a harmonized standard under the WAD, it creates a presumption of conformity: a public sector body whose website or app conforms to EN 301 549 is presumed to comply with the WAD’s accessibility requirements. This simplifies compliance — organizations can use EN 301 549 as their technical target and have legal protection. (BoK p. 62)

Annex A of EN 301 549 is particularly important: it maps the standard’s clauses to WCAG 2.1 success criteria, providing a direct link between the European standard and the internationally recognized web content guidelines. (BoK p. 62)

Real-world example

A EU member state’s tax authority commissions an accessibility audit of its online self-assessment portal. The auditor tests against EN 301 549 V3.2.1 (which references WCAG 2.1 AA via Annex A) and produces a detailed report. The authority then publishes an accessibility statement on the portal listing the findings as known barriers, providing a contact email for users who need accessible alternatives, and committing to a remediation timeline. This satisfies all four WAD requirements: conformance work in progress, published statement, feedback channel, and data available for the member state’s monitoring report.

Key terms

Directive 2016/2102: The EU Web Accessibility Directive; requires public sector websites and apps to be accessible and publish accessibility statements. (BoK p. 61)
Public sector: Under the WAD, 'public sector bodies' include national, regional, and local government entities and related public organizations. (BoK p. 62)
Accessibility statement: A public declaration by a public sector body about its website's conformance status, known gaps, and contact information. (BoK p. 62)
Feedback mechanism: A channel (e.g. a form or email address) on a public sector website that allows users to report accessibility barriers. (BoK p. 62)
EN 301 549: The European harmonized standard for ICT accessibility; Annex A maps to WCAG 2.1; conformance gives presumption of WAD compliance. (BoK p. 62)
Harmonized standard: A European standard whose reference is published in the Official Journal of the EU, creating a presumption of conformity with a directive. (BoK p. 62)
Annex A: The section of EN 301 549 that maps the standard's requirements to WCAG 2.1 success criteria for web content. (BoK p. 62)
WCAG 2.1: Web Content Accessibility Guidelines version 2.1; referenced by EN 301 549 as the web content accessibility benchmark. (BoK p. 62)

Check yourself

The EU Web Accessibility Directive (Directive 2016/2102) applies to public sector bodies. Which of the following is a requirement the WAD imposes on covered entities?

Public sector bodies must publish an accessibility statement describing their conformance status and providing a contact for feedback
Private sector companies must publish WCAG 2.1 conformance reports on their websites
Public sector bodies must use a sign language video player on every web page
Public sector bodies must ensure their websites conform to EN 301 549 but have no obligation to publish any statement

.cy-island-wrapper { display: none; }JavaScript is required for the interactive quiz. Here are the questions for reference:

The EU Web Accessibility Directive (Directive 2016/2102) applies to public sector bodies. Which of the following is a requirement the WAD imposes on covered entities?

a) Private sector companies must publish WCAG 2.1 conformance reports on their websites
b) Public sector bodies must publish an accessibility statement describing their conformance status and providing a contact for feedback — correct answer
c) Public sector bodies must ensure their websites conform to EN 301 549 but have no obligation to publish any statement
d) Public sector bodies must use a sign language video player on every web page

Explanation: The Web Accessibility Directive (Directive 2016/2102) imposes four main requirements on EU public sector bodies: (1) accessible websites and mobile apps conforming to EN 301 549; (2) an accessibility statement disclosing conformance status, known gaps, and contact details; (3) a feedback mechanism allowing users to report barriers; and (4) periodic monitoring and reporting to the European Commission. Publishing an accessibility statement is a specific, named WAD requirement — not optional (BoK p. 62).

A multinational company with offices in both the EU and the US is procuring ICT for its public-facing services. In the EU, the applicable harmonized standard is EN 301 549. In the US, federal agency ICT must meet Section 508 Standards. Which statement correctly identifies a key difference between these two standards regarding WCAG?

a) EN 301 549 references WCAG 2.0; Section 508 Standards reference WCAG 2.1
b) EN 301 549 references WCAG 2.1; Section 508 Standards reference WCAG 2.0 — correct answer
c) Both EN 301 549 and Section 508 Standards reference WCAG 2.1
d) EN 301 549 applies only to software; Section 508 Standards apply only to web content

Explanation: EN 301 549 V3.2.1 — the European harmonized standard used to demonstrate conformance with the Web Accessibility Directive — references WCAG 2.1 through its Annex A. The refreshed Section 508 Standards (effective January 2018) incorporate WCAG 2.0 for web content. This version difference is a frequently tested confusable in Domain Three: EU standard = WCAG 2.1; US federal standard = WCAG 2.0 (BoK p. 62).

A public sector body's legal team asks whether conforming to EN 301 549 automatically means the organization is legally compliant with the Web Accessibility Directive (WAD). Which statement best explains the relationship?

a) Conforming to EN 301 549 gives the organization a presumption of conformity with the WAD, but the WAD also requires an accessibility statement and feedback mechanism — correct answer
b) Conforming to EN 301 549 fully satisfies all WAD requirements with no other obligations
c) EN 301 549 and the WAD are completely independent; conforming to one has no bearing on compliance with the other
d) Conforming to EN 301 549 is only required for private sector companies; public sector bodies use a different standard

Explanation: EN 301 549 is the harmonized standard published under the Web Accessibility Directive. When its reference is published in the EU Official Journal, a public sector body whose website or app conforms to EN 301 549 gets a presumption of conformity with the WAD's accessibility requirements. However, the WAD includes requirements beyond technical accessibility: specifically, publishing an accessibility statement and providing a feedback mechanism. Technical conformance (EN 301 549) addresses one dimension; the accessibility statement and feedback mechanism address others. All must be in place for full WAD compliance (BoK p. 62).

Sources

BoK references

Section 3E — IAAP CPACC Body of Knowledge v4.0 (Oct 2023), p. 61–62

External sources

Directive 2016/2102/EU of the European Parliament and of the Council (Web Accessibility Directive). Accessed October 28, 2026.
EN 301 549 V4.1.1 published (WCAG 2.2). Accessed October 28, 2026.