EN 301 549 Annex ZB is the new annex in V4.1.1 that maps the standard's technical clauses to the essential requirements of the European Accessibility Act, Directive (EU) 2019/882. It has five tables. Tables ZB.1 to ZB.3 cover products, ZB.4 covers every service in scope, and ZB.5 covers the extra duties on specific services such as banking and e-commerce (ETSI EN 301 549 V4.1.1). Each row quotes a line of EAA Annex I and lists the EN 301 549 clauses that satisfy it.
Two things to know before you use it. First, Annex ZB grants nothing yet. It confers a presumption of conformity only once the Commission cites V4.1.1 in the Official Journal of the EU, and as of 22 September 2026 that citation has not been published (AccessibleEU). Second, the standard itself tells you not to use Annex ZB to assess a specific product. For that it points you to clause A.2. Annex ZB is the map. Clause A.2 is the checklist.
What is EN 301 549 Annex ZB?
It is an informative annex titled "Relationship between the present document and the essential requirements of Directive (EU) 2019/882". V4.1.1 was prepared under the Commission's standardisation request C(2022) 6456 final, also known as M/587, specifically to give businesses "one voluntary means of conforming" to the EAA (ETSI EN 301 549 V4.1.1, foreword and clause ZB.0). Annex ZB is where that link is written down, row by row.
EN 301 549 V4.1.1 has three of these annexes:
| Annex | Maps the standard to | Tables |
|---|---|---|
| ZA | Directive (EU) 2016/2102, the Web Accessibility Directive (public sector) | ZA.1 web pages and documents, ZA.2 mobile apps |
| ZB | Directive (EU) 2019/882, the European Accessibility Act | ZB.1 to ZB.5 |
| ZC | Requirements from other directives that refer to EAA Annex I, Section VI | ZC.1 |
Annex ZA is an update of what used to be Annex A in v3.2.1. Annex ZB is entirely new.
What do the five Annex ZB tables cover?
Each table follows one part of EAA Annex I. Every row gives the Annex I reference, the requirement text quoted from the Directive, and the EN 301 549 clauses that address it.
| Table | EAA Annex I section | Applies to |
|---|---|---|
| ZB.1 | Section I, point 1: information on the product | All products in Article 2(1) |
| ZB.2 | Section I, points 2 and 3: user interface, functionality, support services | All products in Article 2(1) |
| ZB.3 | Section II: information about specific products | Products in Article 2(1) except self-service terminals |
| ZB.4 | Section III: general requirements for services | All services in Article 2(2) |
| ZB.5 | Section IV: specific services | Named services, including banking and e-commerce |
The product list in clause ZB.1 reproduces the EAA's Article 2(1) in full, from consumer computers and ATMs to e-readers (ETSI EN 301 549 V4.1.1, clause ZB.1; Directive (EU) 2019/882).
Which Annex ZB rows matter for a website?
If you run an online shop, a bank's web app, or a SaaS product sold to consumers, you live in Tables ZB.4 and ZB.5. The row most people are looking for is ZB.4 row 9. It quotes EAA Annex I, Section III, point (c): "making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust". The clauses it maps to are three: 4.2, 9 and 11.
That is the EAA's web and app requirement in one row. Clause 9 is web content (WCAG 2.2 Level A and AA in V4.1.1), clause 11 is software including mobile apps, and 4.2 is the set of functional performance criteria, such as usage without vision and usage with limited manipulation.
Two other ZB.4 rows are worth reading for web teams:
- Row 6, fonts, contrast and spacing, maps to 9.1.4.3 contrast, 9.1.4.4 resize text, 9.1.4.12 text spacing, and clause 9.7.
- Row 10, support services, maps to 4.2, 11.5.2, 12.3 and 13.1. Your help desk has to be able to tell a customer how the service works with their assistive technology.
Clause 9.7 deserves a sentence of its own, because it is new for the web. It says a page shall not block or explicitly override the user's platform preference settings unless that is essential, and its note gives forced-color-adjust in CSS as the example (ETSI EN 301 549 V4.1.1, clause 9.7). v3.2.1 had user preferences only for software, in clause 11.7 (ETSI EN 301 549 v3.2.1). If your stylesheet sets forced-color-adjust: none on the whole body to protect a brand colour, that is the kind of thing 9.7 is written about.
For e-commerce, Table ZB.5 adds three rows from EAA Annex I, Section IV. One covers providing accessibility information about the products being sold, mapped to 4.2, 5.4 and 12.1 to 12.3. The other two cover identification, security and payment, and they map to clause 5 (especially 5.1 closed functionality) plus clauses 9, 10 and 11. Checkout and login flows are not a side note in the EAA. They have their own rows.
Does Annex ZB give you a presumption of conformity today?
No. Clause ZB.0 is conditional: "Once the present document is cited in the Official Journal of the European Union under that Directive", conformance with the clauses in Tables ZB.1 to ZB.5 confers a presumption of conformity (ETSI EN 301 549 V4.1.1). That mirrors Article 15 of the EAA, which ties the presumption to harmonised standards whose references are published in the Official Journal (Directive (EU) 2019/882).
The Commission's AccessibleEU centre put it plainly on 7 September 2026: until V4.1.1 is formally cited, the current reference remains v3.2.1 from 2021 (AccessibleEU). v3.2.1 is cited through Commission Implementing Decision (EU) 2021/1339 under the Web Accessibility Directive, not the EAA. So today no version of EN 301 549 gives a private company a presumption of conformity with the EAA.
You will see write-ups naming a citation date. The dates printed in the standard (doa 30 November 2026, dop/e 31 May 2027, dow 31 May 2028) are national transposition deadlines for standards bodies, not the Official Journal citation, which is a separate Commission act. Don't plan around a citation date until one is published. The V4.1.1 explainer covers those dates in more detail.
Should you use Annex ZB or clause A.2?
Use clause A.2 for assessing your product. The standard says so in a note under clause ZB.0: because one product or service can fall into several EAA categories, it "might need to meet the essential requirements that are listed in several rows of multiple tables in Annex ZB", which makes the tables "impractical for use in assessing whether a specific ICT product or service meets all the applicable requirements". The note then says "the tables in clause A.2 offer the most appropriate way" (ETSI EN 301 549 V4.1.1).
Clause A.2 works differently. You walk five tables in order and ask one question at each:
- Table A.1: is the ICT, or does it include, a web page?
- Table A.2: a non-web document?
- Table A.3: non-web software with a user interface?
- Table A.4: hardware?
- Table A.5: all ICT, always applies.
Each row gives a clause, a condition and an assessment reference into Annex C. For a web page, Table A.1 lists 9.1.1.1 non-text content through 9.4.1.3 status messages, then 9.6 WCAG conformance and 9.7 user preferences, each assessed by the matching test in Annex C. Once cited, the presumption attaches to the clauses in Tables A.1 to A.5 as well, per clause A.2.0.
My view: Annex ZB is a document for the person writing your compliance file. It lets a lawyer or product owner point from an EAA obligation to the clauses that answer it. Engineers should not work from it. They should work from A.2 and Annex C, because that is where the tests are. I would put both in the file, the A.2 results as the evidence and the ZB rows as the index to that evidence.
What doesn't Annex ZB cover?
Some limits are written into the annex itself.
E-books are the clearest case. The e-books line in Table ZB.5's service list carries NOTE 2: "E-Books which are out of scope of the present document." EN 301 549 is a standard for ICT products and services. It does not define e-book file accessibility, so a publisher will need other standards for the file itself.
Information that isn't digital is the second. Several rows say that EN 301 549 covers information "available in digital forms" and that other harmonised standards may add requirements for the specific kinds of information the EAA lists. Printed labelling and packaging are outside it.
And Annex ZB tells you which clauses apply. It does not do any of the testing. Clause 9 alone means full WCAG 2.2 AA, and automated tools find only part of that. Depending on how you count, automated testing identifies roughly 30 to 57% of issues (Deque). Clause 9.7, for example, needs someone to switch on forced colours or high-contrast mode and look at the page. A scanner can flag the CSS property. It can't judge whether the override was essential.
What should you do now?
Keep testing against WCAG 2.1 AA because v3.2.1 is still the cited version, and add the six WCAG 2.2 criteria plus clause 9.7, because that is where V4.1.1 lands. Then build a small traceability table: for each ZB row that applies to you, list the clauses, the A.2 test result, and the date. When the citation arrives, you change a version reference instead of starting over. Our EN 301 549 checklist walks the clause structure, and the record belongs in your accessibility statement.
Frequently asked questions
What is Annex ZB in EN 301 549?
Annex ZB is the informative annex in EN 301 549 V4.1.1 that maps the standard's clauses to the essential requirements of the European Accessibility Act, Directive (EU) 2019/882. It has five tables: ZB.1 to ZB.3 for products, ZB.4 for all services, and ZB.5 for specific services.
Does Annex ZB give a presumption of conformity with the EAA?
Not yet. It confers a presumption of conformity only once the Commission cites V4.1.1 in the Official Journal of the EU, and that citation had not been published as of 22 September 2026.
What is the difference between Annex ZA and Annex ZB?
Annex ZA maps EN 301 549 to the Web Accessibility Directive for public sector websites and apps. Annex ZB maps it to the European Accessibility Act, which covers private-sector products and services.
Which Annex ZB row covers websites?
Table ZB.4 row 9 covers websites and mobile applications. It quotes EAA Annex I, Section III, point (c) and maps it to clauses 4.2, 9 and 11 of EN 301 549.
Should I use Annex ZB to test my product?
No. The standard's own note says Annex ZB is impractical for assessing a specific product and recommends the tables in clause A.2 instead, with each test defined in Annex C.
Check the web clauses first
Clause 9 is where most EAA work sits for a website. Run a free scan to find the machine-detectable WCAG issues on your key pages, then do the manual checks a scanner can't judge, clause 9.7 among them, and write the results down against the A.2 rows.
Pavel Charkasau, founder, wcagc.com. Last updated 22 September 2026.
Sources
- EN 301 549 V4.1.1 (2026-09), ETSI/CEN/CENELEC: foreword (standardisation request C(2022) 6456 final; Annex ZB added; national transposition dates); introduction (Annex ZA/ZB/ZC structure); clause 9.7 user preferences for web pages; clause A.2.0 to A.2.5 and Tables A.1 to A.5; Annex ZB clauses ZB.0 to ZB.5 and Tables ZB.1 to ZB.5, including ZB.4 rows 6, 8, 9 and 10, the ZB.5 e-commerce rows, and ZB.5 NOTE 2 on e-books. Accessed 22 September 2026.
- EN 301 549 v3.2.1 (2021-03), ETSI/CEN/CENELEC: user preferences only at clause 11.7 (software); no clause 9.7. Accessed 22 September 2026.
- The European accessibility standard EN 301 549 has been updated, AccessibleEU (European Commission), 7 September 2026: V4.1.1 published in September 2026; v3.2.1 remains the reference until formal citation. Accessed 22 September 2026.
- Directive (EU) 2019/882, EUR-Lex: Article 2 scope, Article 15 presumption of conformity, Annex I requirements. Accessed 22 September 2026.
- Commission Implementing Decision (EU) 2021/1339, EUR-Lex: citation of EN 301 549 v3.2.1 under the Web Accessibility Directive. Accessed 22 September 2026.
- Automated testing identifies 57% of accessibility issues, Deque: automated coverage figures. Accessed 22 September 2026.