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EAAWCAGEN 301 549

EAA vs WCAG: how they actually relate

EAA vs WCAG, explained: WCAG is the technical standard, EN 301 549 wraps it, and the EAA is the law that references it. How they fit together.

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Pavel Charkasau

The short answer to "EAA vs WCAG" is that they are not two options you choose between. They sit on different layers. WCAG is a set of technical guidelines from the World Wide Web Consortium (W3C) that tells you, in testable detail, what makes web content accessible. The European Accessibility Act (the EAA, Directive (EU) 2019/882) is an EU law that says certain products and services must be accessible, and it has applied since 28 June 2025. The law does not spell out the technical detail itself. It points to a harmonised European standard, EN 301 549, and EN 301 549 in turn incorporates WCAG for the web part. So the real picture is a chain, not a contest: the EAA is the legal obligation, EN 301 549 is the standard that satisfies it, and WCAG 2.1 Level AA is the web content bar inside that standard. Meet EN 301 549 and you get a legal presumption of conformity with the EAA. This guide walks through each layer and where WCAG stops and the law begins.

Is the EAA the same thing as WCAG?

No. They answer different questions. WCAG answers "what does accessible web content look like, and how do I test it?" The EAA answers "who is legally required to be accessible, for which products and services, in the EU?" One is a technical yardstick; the other is a statute with obligations, enforcement bodies, and paperwork.

That difference matters in practice. You can conform to WCAG and still have EAA duties you have not met, because the law asks for things WCAG never mentions, like publishing an accessibility statement and, for products, keeping conformity documentation. And you can be subject to the EAA while your team only ever talks in WCAG terms, because the web-facing work you do to satisfy the law is, in day-to-day terms, WCAG work. The two overlap heavily on the web. They are not the same thing.

What is WCAG?

WCAG stands for the Web Content Accessibility Guidelines. The W3C's Web Accessibility Initiative publishes it, and it is the reference the whole field builds on (W3C). It is organised into success criteria, each a specific, checkable requirement, grouped under three conformance levels: A is the minimum, AA is the level almost every law and contract asks for, and AAA is the strictest and rarely required in full.

There are three versions in current use. WCAG 2.0 dates from 2008, 2.1 added criteria for mobile, low vision, and cognitive accessibility in 2018, and 2.2 became a W3C Recommendation on 5 October 2023, adding nine more success criteria on top of 2.1 (W3C). At Level A and AA combined, WCAG 2.1 has around 50 success criteria. Crucially, WCAG is not a law and carries no obligation on its own. It is a technical document that laws and standards choose to reference. On its own it never asks you to file a statement, register with a regulator, or keep records. Those requirements come from the legal layer sitting above it.

What is the EAA, and what does it actually require?

The European Accessibility Act is Directive (EU) 2019/882. It sets accessibility requirements for a defined list of products and services sold to consumers in the EU: e-commerce, consumer banking, e-books, electronic communications, transport services, and hardware like computers, e-readers, and self-service terminals. It reaches manufacturers, importers, distributors, and service providers, and it applies by market, so a business outside the EU that sells into the EU is in scope for those sales (European Commission). We cover who is caught and who is exempt in our EAA overview.

The EAA describes accessibility in functional terms, the outcomes a product or service has to deliver, rather than a list of code-level checks. That is deliberate. Directives set the goal and leave the technical detail to standards, which can be updated without reopening the law. To bridge that gap, the EAA uses the mechanism in Article 15: conformity with a harmonised standard cited in the Official Journal creates a presumption of conformity with the directive's requirements. That is the hinge the whole "EAA vs WCAG" question turns on, and the standard on the other side of it is EN 301 549.

How does EN 301 549 connect the EAA and WCAG?

EN 301 549 is the European standard for the accessibility of ICT products and services, developed jointly by the European standards bodies CEN, CENELEC, and ETSI. It is the "how" that the EAA's "what" relies on. The current referenced version, EN 301 549 v3.2.1 (published March 2021), incorporates WCAG 2.1 Level AA for web content in its Chapter 9. In effect, WCAG 2.1 AA is lifted straight into the European standard as the web requirement.

So the layers stack like this. The EAA says be accessible. EN 301 549 defines what accessible means for ICT and, for anything web-facing, defers to WCAG 2.1 AA. WCAG defines the individual, testable success criteria. Satisfy the relevant EN 301 549 clauses and you earn the presumption of conformity with the EAA. WCAG sits at the bottom of that stack doing the technical heavy lifting.

EN 301 549 is also wider than WCAG. WCAG covers web content; EN 301 549 covers hardware, non-web software, documentation, and features like real-time text and two-way voice communication that WCAG never addresses. If your product is only a website, the WCAG part is most of what applies to you. If it is a kiosk, a phone, or a native app, EN 301 549 asks for things WCAG cannot, because those things live outside the web. The standard also carries Annex C, a clause-by-clause checklist you can use to record whether each applicable requirement is met, partially met, or not met, which is the natural backbone of an accessibility statement.

Which version of WCAG does the EAA require?

Today, WCAG 2.1 Level AA, because that is the version baked into EN 301 549 v3.2.1, the harmonised version the EAA relies on. So the working legal bar right now is 2.1 AA, not 2.2. That surprises teams who assume the newest WCAG is automatically the required one. It is not, because the law tracks the standard, and the standard tracks a specific frozen version of WCAG.

This will move. An updated EN 301 549 v4.1.1, prepared under European Commission standardisation request M/587, is expected to incorporate WCAG 2.2 and was in progress through 2026. The sensible planning position is to build to WCAG 2.1 AA as today's requirement while designing with WCAG 2.2's additions in mind, so the eventual shift is a small step rather than a rebuild. Our checklist tool tracks against 2.1 AA and flags where 2.2 adds something new.

If I fully meet WCAG, am I EAA compliant?

Meeting WCAG 2.1 AA on your website covers the largest single part of the web-facing obligation, but it does not, by itself, make you EAA compliant. Three gaps remain.

First, the EAA asks for more than working web pages. Service providers must publish an accessibility statement describing how the service meets the requirements, and product economic operators have to prepare and keep conformity documentation. WCAG never asks for either. Second, if your product reaches beyond the web, into an app, a device, or a self-service terminal, EN 301 549 has requirements that WCAG does not cover, and those apply regardless of how clean your website is. Third, "meeting WCAG" is harder to prove than it sounds. Automated tools catch only part of the picture. Deque's analysis of more than 2,000 audits found automation identified about 57% of issues by volume, while estimates based on the share of success criteria a scanner can even evaluate put the figure closer to 30% (Deque). Either way, a real portion of WCAG can only be confirmed by a person testing with a keyboard and a screen reader.

This is where honesty matters. No scanner, and no overlay widget, can confirm WCAG conformance on its own, and claiming otherwise is what earned the overlay vendor accessiBe a $1 million order from the US Federal Trade Commission for representing that its product made sites WCAG compliant (FTC). The practical route is to fix what a scanner can find, review the rest by hand, and document where you stand.

Frequently asked questions

Is the EAA the same as WCAG?

No. WCAG is a set of technical guidelines from the W3C for accessible web content. The EAA is an EU law that requires certain products and services to be accessible. The law references the EN 301 549 standard, which incorporates WCAG 2.1 AA for the web, so they connect but are not the same.

Does the EAA require WCAG 2.1 or 2.2?

WCAG 2.1 Level AA, for now. That is the version built into EN 301 549 v3.2.1, the harmonised standard the EAA relies on. An updated EN 301 549 (v4.1.1) is expected to bring in WCAG 2.2, but 2.1 AA is the working legal bar today.

If my site meets WCAG 2.1 AA, is it EAA compliant?

Meeting WCAG 2.1 AA covers most of the web-facing requirement, but not all EAA duties. The law also expects an accessibility statement, and for products, conformity documentation, and EN 301 549 adds requirements for non-web ICT that WCAG does not cover.

What is EN 301 549's role between the two?

EN 301 549 is the bridge. It is the harmonised European standard the EAA points to, it incorporates WCAG 2.1 AA for web content, and it adds accessibility requirements for hardware, software, and documentation. Meeting it gives a presumption of conformity with the EAA.

Is WCAG legally binding?

Not by itself. WCAG is a technical standard with no legal force on its own. It becomes binding when a law or contract references it, which is exactly what the EAA does indirectly, through EN 301 549.

See where your site actually stands

If you are working out your EAA position, the useful first move is to measure your website against WCAG 2.1 AA, since that is the bar EN 301 549 sets for the web. Run a free scan to surface the machine-detectable issues on your key pages, then work through the manual checks for what a scanner cannot judge. You will have a real baseline to act on, and the evidence to write an honest accessibility statement instead of a guess.

Pavel Charkasau, founder, wcagc.com. Last updated 1 July 2026.

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