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EN 301 549presumption of conformityWeb Accessibility Directive

EN 301 549 Annex A and presumption of conformity

EN 301 549 Annex A links the standard to the Web Accessibility Directive: what its presumption-of-conformity tables mean, and how the EAA differs.

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Pavel Charkasau

EN 301 549 Annex A is the part of the European accessibility standard that connects it to the law. It holds two tables, A.1 for web pages and documents and A.2 for mobile applications, that map the standard's technical clauses to the essential requirements of the EU Web Accessibility Directive. Meet the clauses those tables list, and once the standard's reference is published in the Official Journal of the EU, you get a presumption of conformity with the directive (ETSI EN 301 549 v3.2.1). That presumption is the whole point of Annex A. It is the legal bridge that turns "we passed these technical clauses" into "we are presumed to satisfy the law." Three things trip people up, and this guide covers each. Annex A is labelled informative, yet the clauses it points to are normative and mandatory. The presumption it grants is written for Directive (EU) 2016/2102, the public sector Web Accessibility Directive, not automatically for the European Accessibility Act. And the presumption only holds while the standard's reference stays listed in the Official Journal. Here is what each table covers, what the presumption means in practice, and where the EAA sits differently today.

What is EN 301 549 Annex A?

Annex A is titled "Relationship between the present document and the essential requirements of Directive 2016/2102," and it does exactly that. The main body of EN 301 549 is a long list of technical requirements for information and communication technology: web content, native software, mobile apps, documents, hardware, and closed products like ticket machines. On its own, that list is just engineering detail. Annex A is what ties a subset of it to a specific EU law.

It does the tying with two tables. Each row takes a clause of the standard and lines it up against one of the four essential requirements the directive borrows from WCAG: perceivable, operable, understandable, robust. So Annex A is not new requirements. It is a lookup that says: for the Web Accessibility Directive, these are the clauses that count, and here is which legal requirement each one supports (ETSI EN 301 549 v3.2.1).

What does "presumption of conformity" actually mean?

It means the law lets you prove compliance the easy way. Article 4 of the Web Accessibility Directive states the outcome in four words, perceivable, operable, understandable, robust, and names no success criteria. Article 6 then adds the shortcut: content that meets the relevant harmonised standard, or the relevant parts of it, is presumed to conform to those requirements (Directive (EU) 2016/2102). You do not have to argue from first principles that your site is accessible. You show you met the clauses, and the burden shifts.

Annex A is where the standard names those clauses. Its own wording is precise about the trigger: "Once the present document is cited in the Official Journal of the European Union under that Directive, conformance with the normative clauses of the present document given in Tables A.1 and A.2 confers, within the limits of the scope of the present document, a presumption of conformity with the corresponding essential requirements of that Directive" (ETSI EN 301 549 v3.2.1). Two conditions have to hold at once. The standard has to be cited in the Official Journal, and you have to meet the Table A.1 or A.2 clauses.

The European Commission handled the citation with an implementing decision. Commission Implementing Decision (EU) 2018/2048 first listed EN 301 549 in the Official Journal for the directive, and Commission Implementing Decision (EU) 2021/1339 updated that reference to v3.2.1 in August 2021. So for the public sector, the presumption is live right now, and it runs on version 3.2.1.

One detail people miss: the presumption is only as durable as the listing. The standard says it plainly, that a presumption of conformity "stays valid only as long as a reference to the present document is maintained in the list published in the Official Journal" (ETSI EN 301 549 v3.2.1). When a new version supersedes the old one, the reference changes, and the version that carries the presumption changes with it.

What do Tables A.1 and A.2 cover?

Table A.1 is the web table. It applies to web pages and both embedded and downloadable documents, and it maps the clauses that matter for those to the essential requirements. In practice the bulk of Table A.1 points at Chapter 9, which is WCAG 2.1 Level AA renumbered with a "9." prefix, and it pulls in supporting clauses from elsewhere in the standard, such as the general clauses in 5, 6, 7, and 12. Clause 9.1.4.3 is WCAG 1.4.3 Contrast (Minimum); clause 9.2.4.7 is WCAG 2.4.7 Focus Visible. If you have run a WCAG 2.1 AA audit on your pages, you have already done most of Table A.1.

Table A.2 is the mobile table. It applies to mobile applications and maps the clauses relevant to them, which lean on Chapter 11 for software and reuse many WCAG criteria through it (ETSI EN 301 549 v3.2.1). Mobile is not just "WCAG for apps," though. Some of what an app has to satisfy sits in software clauses that WCAG never wrote, so a pure WCAG pass does not automatically clear Table A.2.

Here is the part worth underlining. Requirements that are in EN 301 549 but not listed in Table A.1 or A.2 are still part of the standard. They just do not carry the directive's presumption of conformity (ETSI EN 301 549 v3.2.1). So the tables are a legal shortlist, not the full standard. For a government website, the shortlist is what a national monitoring body checks you against.

Is Annex A normative or informative?

Annex A is informative, but the clauses it references are normative. That sounds like a contradiction and it is the single most common misreading of the standard, so it is worth slowing down on.

"Informative" means the annex itself is explanatory rather than a set of requirements you have to meet. You cannot fail Annex A. What you can fail is a clause in the main body, say 9.1.4.3, and those clauses are normative, which means mandatory. Annex A's job is to tell you which of the normative clauses are the ones the Web Accessibility Directive cares about. The annex is a map; the territory it maps is binding. So when a checklist says "conform to Annex A," what it really means is "conform to the normative clauses that Tables A.1 and A.2 point to." Our WCAG checklist tracks the web-content side of that list, the Chapter 9 clauses, against WCAG 2.1 AA.

Does Annex A give a presumption of conformity under the EAA?

Not yet, and this is where a lot of vendor pages get sloppy. Annex A is written for one law: Directive 2016/2102, the Web Accessibility Directive, which covers the public sector. The European Accessibility Act (Directive (EU) 2019/882) is a separate law for the private sector, and it has its own presumption mechanism in Article 15: conformity is presumed where you meet harmonised standards whose references are published in the Official Journal under the EAA.

The catch is that, as of mid-2026, no harmonised standard has been cited in the Official Journal under the EAA. The Commission issued a standardisation request to revise EN 301 549 for the Act, and that revision is still in progress (European Commission, Rolling Plan for ICT Standardisation). A draft, EN 301 549 v4.1.0, went out for public comment in November 2025, and the WCAG 2.2-aligned version expected to follow is anticipated to be referenced in the Official Journal around October 2026 (ETSI EN 301 549 v4.1.0 draft).

So the honest reading: under the EAA today, EN 301 549 is the best technical reference you have, and meeting it is strong evidence, but it is not yet the automatic legal presumption that the Web Accessibility Directive already grants the public sector. I still build private-sector products to EN 301 549 now. The requirements are not going to shrink, and retrofitting is slower than getting it right the first time. Just do not tell an auditor you have a formal presumption of conformity under the EAA that the Official Journal has not yet created.

How is Annex A different from Annex B and Annex C?

Three annexes, three jobs. Annex A answers "which clauses earn a presumption for the directive?" Annex B answers "which requirement serves which user need?" by mapping clauses to the functional performance statements in clause 4. Annex C, "Determination of conformance," answers "have I actually met each clause?" by giving every requirement a pre-condition and a pass/fail test (ETSI EN 301 549 v3.2.1). So the workflow reads left to right: Annex A gives you the shortlist, Annex C tells you whether you passed each item on it. We cover the testing side in what is EN 301 549 Annex C.

None of these three can be settled by a scanner alone. Deque's analysis of more than 2,000 audits found automation identified about 57% of issues by volume, and estimates based on how many success criteria a tool can even evaluate put the figure closer to 30% (Deque). The rest, focus order, meaningful alt text, whether an error message actually helps, needs a person with a keyboard and a screen reader. That is also why no scanner or overlay can declare your site conformant on its own. 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).

Frequently asked questions

Is EN 301 549 Annex A normative or informative?

Informative. The annex explains the relationship between the standard and the Web Accessibility Directive, so you cannot fail Annex A itself. The clauses it points to in Tables A.1 and A.2 are normative, meaning mandatory, and those are what you actually have to meet.

What is the difference between Table A.1 and Table A.2?

Table A.1 covers web pages and documents; Table A.2 covers mobile applications. Each maps the standard's clauses to the four essential requirements of Directive 2016/2102. Table A.1 leans on Chapter 9 (WCAG 2.1 AA), while Table A.2 leans on Chapter 11 software clauses.

Does meeting Annex A give a presumption of conformity under the EAA?

Not automatically. Annex A's presumption is written for the Web Accessibility Directive, and EN 301 549 v3.2.1 is cited in the Official Journal for that law. Under the European Accessibility Act, no harmonised standard has yet been cited in the Official Journal, so the formal presumption is still pending.

Which version of EN 301 549 carries the presumption today?

Version 3.2.1, for the Web Accessibility Directive, cited via Commission Implementing Decision (EU) 2021/1339 in August 2021. The presumption stays valid only while that reference is maintained in the Official Journal, so it will move to a newer version when one is cited.

Do I still have to meet clauses not listed in Annex A?

They are part of EN 301 549, but they do not carry the directive's presumption of conformity. Whether you must meet them depends on which law and scope apply to your product. Annex A tells you the shortlist that matters for the Web Accessibility Directive specifically.

Check your site against the Annex A web clauses

The largest block of Table A.1 is Chapter 9, which is WCAG 2.1 AA. That is the practical place to start. Run a free scan to clear the machine-detectable checks on your key pages, then work through the manual criteria a scanner cannot judge. You will have real, clause-level results to record in an accessibility statement, instead of a guess about whether you meet the clauses Annex A actually lists.

Pavel Charkasau, founder, wcagc.com. Last updated 31 July 2026.

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