An EN 301 549 checklist for 2026 has two halves: work out which of the standard's clauses actually apply to your product, then test each applicable requirement and record whether you met it. The standard is organised by type of technology, not by a single flat list, so the first job is scoping. Clause 9 covers web content and adopts WCAG 2.1 Level A and AA in full, which is where most website teams spend their time (ETSI EN 301 549 v3.2.1). Other clauses cover hardware, documents, software, two-way voice, video, and support services. You only check the ones your product triggers. For 2026, the legal reference is still v3.2.1, so you test against WCAG 2.1 AA today, while a v4.1.1 update aligned with WCAG 2.2 is expected to be cited in the Official Journal around October 2026 (European Commission). This guide walks the checklist clause by clause, shows what maps to WCAG, and explains how to record each result honestly as met, not met, or not applicable, and what an automated scan can and cannot settle.
Which version of EN 301 549 does the 2026 checklist follow?
Version 3.2.1, published in March 2021. It is the harmonised standard currently referenced for both the European Accessibility Act and the earlier Web Accessibility Directive, and its Chapter 9 incorporates WCAG 2.1 Level A and AA in their entirety (ETSI EN 301 549 v3.2.1). So a checklist built for 2026 tests web content against the 50 WCAG 2.1 A and AA success criteria, plus the non-web requirements that apply to your product.
A change is on the way. ETSI released a draft, EN 301 549 v4.1.0, for public comment in November 2025, and the final v4.1.1 is expected to be referenced in the Official Journal around October 2026 (ETSI EN 301 549 v4.1.0 draft). The main change for the web is that Chapters 9, 10, and 11 move up to align with WCAG 2.2, which adds success criteria on top of 2.1. Until that version is cited, v3.2.1 and WCAG 2.1 AA remain the yardstick. The sensible planning position for 2026: test against 2.1 AA now, and read WCAG 2.2's additions so the eventual step up is small.
Which EN 301 549 clauses apply to your product?
EN 301 549 is self-scoping. Almost every requirement is written as "Where ICT «pre-condition», it shall «do something»", so a requirement only applies when its pre-condition is true for your product (ETSI EN 301 549 v3.2.1). A website with no video does not fail the captions requirement. The pre-condition is false, so that requirement is simply not applicable. Scoping is the first checklist step, and it removes large blocks of the standard for most products.
Here is the clause map to scope against:
| Clause | Applies when your product… | What to check |
|---|---|---|
| 4 — Functional performance | Always (it frames the rest) | The user-need statements: use without vision, with limited vision, without hearing, without speech, with limited manipulation or strength, and more |
| 5 — Generic | Always | Cross-cutting rules: closed functionality, biometrics, preserving accessibility information, avoiding activation of seizure triggers |
| 6 — Two-way voice | Offers calling or messaging | Real-time text, caller ID, video communication quality |
| 7 — Video | Plays video with audio | Captions and audio description delivery and controls |
| 8 — Hardware | Is a physical device | Keys, controls, connectors, tactile and mechanical access |
| 9 — Web | Has a website or web app | WCAG 2.1 Level A and AA, in full |
| 10 — Documents | Ships non-web documents (PDF, Office) | WCAG success criteria applied to documents, plus document-specific rules |
| 11 — Software | Has non-web software or a mobile app | WCAG applied to software, plus software-specific rules |
| 12 — Documentation and support | Has manuals or a support channel | Accessible documentation; support staff who know the product's accessibility features |
| 13 — Relay and emergency | Connects to relay or emergency services | Access to relay services and emergency communication |
Clause 4 and clause 5 are the two that apply to essentially everyone (ETSI EN 301 549 v3.2.1). For a typical website or web application with no hardware, no phone features, and no downloadable documents, the working scope narrows to clauses 4, 5, 9, and 12. That is a much shorter checklist than the full standard.
What's on the web-content checklist (clause 9)?
Clause 9 is WCAG 2.1 Level A and AA, criterion for criterion. The clause numbers even line up: EN 301 549 clause 9.X.Y.Z is WCAG success criterion X.Y.Z with a "9." prefix (ETSI EN 301 549 v3.2.1). So the web-content half of your checklist is the WCAG 2.1 AA checklist, grouped under WCAG's four principles:
- Perceivable: text alternatives for images, captions for video, sufficient colour contrast (4.5:1 for normal text), content that reflows and resizes.
- Operable: everything reachable and usable by keyboard, a visible focus indicator, no keyboard traps, page titles and clear link text, enough time to complete tasks.
- Understandable: a declared page language, predictable navigation, labels and instructions on inputs, clear error identification and suggestions.
- Robust: valid, parseable markup and correct name, role, and value for custom components so assistive technology can read them.
Our WCAG checklist lays out the full 2.1 AA set so you can work through clause 9 item by item. Clauses 10 and 11 reuse the same WCAG success criteria (interpreted for documents and software through the W3C's WCAG2ICT guidance) and then add a handful of requirements WCAG never covers, such as document and software behaviour beyond the web (ETSI EN 301 549 v3.2.1). If you ship PDFs or a mobile app, those clauses come into scope on top of clause 9.
How do you record each result?
Requirement by requirement, using one of three outcomes: met, not met, or not applicable. This is what Annex C of EN 301 549 defines. Annex C is the normative annex that pairs each requirement's pre-condition with a pass/fail test: if the pre-condition is true and the test passes, the requirement is met; if the test fails, it is not met; and if the pre-condition is false, the requirement is not applicable (ETSI EN 301 549 v3.2.1). Recording that outcome for each in-scope requirement is what turns a checklist into evidence.
That record feeds directly into an accessibility statement, which the EAA requires for services in scope. A statement documents your level of conformance, the parts that are not yet met, and how someone can report a problem. It documents your efforts and known limitations; it is not a claim that everything passes. The per-requirement results from your Annex C checklist are what make the statement honest and specific rather than a guess.
One caution: Annex C tells you the condition that counts as a pass, not the procedure for running the test. You still need to know how to test with a keyboard and a screen reader to apply it. A checklist tells you what to check; it does not replace knowing how to check it.
Can an automated scan complete the EN 301 549 checklist?
No. A scan clears part of it, and a person has to finish the rest. Automated tools reliably settle the machine-detectable checks: missing text alternatives, low colour contrast, missing form labels, some markup errors. They cannot judge whether focus order is logical, whether an error message is genuinely helpful, or whether a caption is accurate.
The coverage is measurable. 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 tool can even evaluate put the figure closer to 30% (Deque). Either way, roughly half the checklist needs manual testing. No scanner, and no overlay widget, completes EN 301 549 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).
The workable route for 2026: scope your clauses, run a scan to clear the machine-detectable checks on your key pages, work the manual criteria a scanner cannot judge, then record the Annex C result for each and write it into a statement.
Frequently asked questions
What version of EN 301 549 applies in 2026?
Version 3.2.1, published in March 2021. It is the harmonised standard currently referenced for the EAA and the Web Accessibility Directive, and its Chapter 9 adopts WCAG 2.1 Level A and AA. A v4.1.1 update aligned with WCAG 2.2 is expected to be cited in the Official Journal around October 2026, after which it would replace v3.2.1.
Is EN 301 549 the same as WCAG 2.1 AA?
Not quite. For web content, Chapter 9 of EN 301 549 incorporates WCAG 2.1 Level A and AA in full, so the web part is the same. But EN 301 549 is broader. It also covers hardware, documents, software, two-way voice, video, and support services, which WCAG does not address.
How do I know which clauses apply to my product?
Read each requirement's pre-condition. EN 301 549 is self-scoping: requirements start with "Where ICT «pre-condition»", and a requirement only applies when that pre-condition is true. A website with no video, no phone features, and no downloadable documents typically scopes down to clauses 4, 5, 9, and 12.
Can I pass the EN 301 549 checklist with an automated tool?
No. Automated testing identifies roughly 30–57% of issues depending on how you count. The rest, such as logical focus order, meaningful alt text, and helpful error messages, needs manual testing with a keyboard and screen reader. A scan is a starting point, not a full conformance check.
Does EN 301 549 require an accessibility statement?
WCAG itself does not, but the EAA and the Web Accessibility Directive do for services in scope. The statement documents your conformance level, known limitations, and a way to report problems. The per-requirement results from your Annex C checklist are what it is built on.
Start with the web-content clause
For most teams, the largest and most testable block of the EN 301 549 checklist is clause 9: the WCAG 2.1 AA criteria for web content. That is the practical place to begin. Run a free scan to clear the machine-detectable checks on your key pages, then work through the manual criteria a scanner cannot judge and record each Annex C result. You will finish with real, requirement-level evidence to put in an accessibility statement, instead of a guess about where you stand.
Pavel Charkasau, founder, wcagc.com. Last updated 6 July 2026.
Sources
- EN 301 549 v3.2.1 (2021-03), ETSI — clause structure (4 through 13), the self-scoping "Where ICT" pre-condition, Chapter 9 incorporation of WCAG 2.1 Level A and AA, and Annex C determination of conformance (met / not met / not applicable). Accessed 6 July 2026.
- Draft EN 301 549 v4.1.0 (2025-11), ETSI — draft update aligning Chapters 9, 10, and 11 with WCAG 2.2. Accessed 6 July 2026.
- Web accessibility standards — latest changes, European Commission — EN 301 549 v3.2.1 as the harmonised standard and the expected v4.1.1 Official Journal citation. Accessed 6 July 2026.
- Automated testing identifies 57% of accessibility issues, Deque — automated coverage figures across more than 2,000 audits. Accessed 6 July 2026.
- FTC approves final order requiring accessiBe to pay $1 million, Federal Trade Commission — deceptive WCAG-compliance claims. Accessed 6 July 2026.