EN 301 549 ICT requirements beyond the web

EN 301 549 is not a web standard with hardware bolted on. Clause 9 covers web pages and it is the part most people have read, but the standard has fourteen clauses (ETSI EN 301 549 V3.2.1). Clauses 5 to 8 apply to ICT that is not a web page at all: a payment terminal, a ticketing machine, a desk phone, a set-top box, an e-reader. Clause 5 sets generic requirements for any ICT, including the rules for closed functionality, where the user cannot attach their own screen reader. Clause 6 covers two-way communication and real-time text. Clause 7 covers captions and audio description in ICT that handles video. Clause 8 is hardware: reach ranges, speech volume, tactile markings, connection ports. If your product has a physical enclosure or a phone line behind it, clause 9 will not tell you whether it conforms. What follows is a walk through the EN 301 549 ICT requirements outside the web chapter, and a note on which version of the standard applies right now.

Which parts of EN 301 549 are not about web pages?

The standard's own introduction sets it out: clauses 5 to 13 "provide specific testable criteria for accessible ICT, related to technical requirements for different kinds of ICT, starting with generic requirements in clause 5" (ETSI EN 301 549 V3.2.1). Web is one of nine.

Most clauses are self-scoping. They open with "Where ICT has…" or "Where ICT is…", and if that condition is false for your product the requirement does not apply. Clause 12 is the exception, and it applies to everything.

What is in clause 5, the generic requirements?

Clause 5 is short and it catches almost everyone, because clause 8.1.1 says plainly that "the generic requirements of clause 5 also apply to ICT that is hardware".

The nine sub-clauses in V3.2.1:

• 5.1 Closed functionality. Where the ICT is closed, it has to meet clauses 5.2 to 13 as applicable, and clause 5.1 supplies the substitutes for anything that assumed assistive technology could be attached. Clause 5.1.4 is the one to read if you build kiosks: where functionality is closed to text enlargement, a non-accented capital "H" has to subtend an angle of at least 0,7 degrees at the viewing distance the supplier specifies.
• 5.2 Activation of accessibility features. A documented accessibility feature has to be activatable without relying on a method that does not support the need it exists for. A screen-reader mode you can only switch on by reading a screen fails this.
• 5.3 Biometrics. No single biological characteristic as the only means of identification or control.
• 5.4 Preservation of accessibility information during conversion. Convert a file and the accessibility information travels with it, as far as the destination format allows.
• 5.5 Operable parts. Anything needing grasping, pinching or twisting of the wrist needs an alternative that does not, and every operable part has to be discernible without vision.
• 5.6 Locking or toggle controls. Caps Lock is the standard's own example. Visual status needs a tactile or audible equivalent, and the other way round.
• 5.7 Key repeat. Where key repeat cannot be turned off, the delay has to be adjustable to at least 2 seconds and the repeat rate down to one character per 2 seconds.
• 5.8 Double-strike key acceptance. The delay during which a repeated identical keystroke is ignored has to be adjustable up to at least 0,5 seconds.
• 5.9 Simultaneous user actions. Two hands or two fingers to operate something? There has to be a mode that needs neither.

Clauses 5.7 and 5.8 look obscure until you notice how many self-service terminals ship with a physical keypad and no way to change either setting.

What does clause 8 require of hardware?

Clause 8 is the physical layer, and a good share of it is measured in millimetres and newtons rather than assessed on screen. In V3.2.1:

• 8.1.2 Standard connections. At least one input or output connection in an industry standard non-proprietary format, directly or through a commercially available adapter. This is what lets someone plug in their own equipment.
• 8.2.1 Speech volume gain. Hardware with speech output has to offer at least 18 dB of volume adjustment, and where the control is incremental, at least one intermediate step at 12 dB above the lowest setting.
• 8.2.2 Magnetic coupling. Devices normally held to the ear need magnetic coupling for hearing aids, against ETSI ES 200 381-1 or ES 200 381-2.
• 8.3 Stationary ICT. Reach ranges for anything floor-standing. With no obstruction, at least one of each type of operable part sits no higher than 1 220 mm and no lower than 380 mm above the floor of the access space.
• 8.4.1 Numeric keys. The number five key on a rectangular keypad has to be tactilely distinct.
• 8.4.2.2 Force of operation. A control needing more than 22,2 N needs an alternative that needs less.
• 8.4.3 Keys, tickets and fare cards. Orientation that matters for use has to be discernible by touch. That notch in a hotel key card is this requirement.
• 8.5 Tactile indication of speech mode. On shared-use ICT with speech output, you have to be able to find the way to start speech mode by touch.

None of this appears anywhere in WCAG, and no amount of work on your website moves any of it.

Which clauses apply to a self-service terminal?

A kiosk is where the non-web clauses stack up. Clause 8 applies because it is hardware. Clause 5.1 applies because it is usually closed to assistive technology. Behind the screen there is software, which is clause 11, and if the thing offers a call or video assistance you pick up clauses 6 and 7 as well.

The European Accessibility Act names these products directly. Article 2(1) covers payment terminals and self-service terminals dedicated to services under the Directive: automated teller machines, ticketing machines, check-in machines, and interactive information terminals other than those built into vehicles, aircraft, ships or rolling stock. It also covers consumer general purpose computer hardware and its operating systems, consumer terminal equipment for electronic communications or for access to audiovisual media services, and e-readers (Directive (EU) 2019/882, reproduced in EN 301 549 V4.1.1 Annex ZB). A company can be squarely in scope of the EAA without operating a web page that matters.

Can an automated tool test clauses 5 to 8?

No, and I would rather say that plainly than sell an audit we cannot run. Our scanner crawls web pages and returns each violation with the CSS selector that caused it. It cannot measure 22,2 N of button force or check that a capital "H" subtends 0,7 degrees.

Annex C is normative and gives the conformance procedure for each requirement, and its labels tell you what kind of work each one is. Procedures are marked Inspection, Inspection and measurement, Testing, or Inspection based on measurement data. Speech volume at clause 8.2.1.1 is the last of those: either the device is certified to ANSI/TIA-4965, or someone measures the level in dB. Nothing in Annex C is run by a scanner.

That sits alongside the coverage number we quote everywhere. Automated testing identifies roughly 30% to 57% of accessibility issues, measured by Deque across more than 2,000 audits (Deque). For clauses 5 to 8 the real figure is lower, because the requirements are physical. Full conformance needs human review, and for hardware it needs a tape measure.

Which version of EN 301 549 applies right now?

V3.2.1, from March 2021. It is the version cited in the Official Journal for the Web Accessibility Directive through Commission Implementing Decision (EU) 2018/2048 as amended by (EU) 2021/1339, so it is the version that carries a presumption of conformity.

V4.1.1 was adopted on 24 August 2026 and published by ETSI in September 2026 (ETSI EN 301 549 V4.1.1). It is not yet cited in the Official Journal, and its own Annex ZB says so in the conditional: once the document is cited, the listed clauses will confer a presumption of conformity with the EAA's essential requirements. The foreword sets 30 November 2026 as the date of latest announcement and 31 May 2028 for withdrawal of conflicting national standards.

For the non-web clauses, V4.1.1 changes more than the WCAG 2.2 alignment people talk about:

• Clause 6 is renamed "ICT supporting real-time bidirectional communication" and gains a total conversation requirement at 6.7.
• Clause 7 now says subtitles where V3.2.1 said captions.
• Clause 8.3 on stationary ICT grows from seven sub-clauses to fourteen and splits into two sets: Set 1 for ICT with no functional or design restrictions, Set 2 for ICT that cannot meet Set 1. Display screens get a rule of their own at 8.3.2, where no part of the display may sit below 800 mm above the floor.
• Clause 8.8, contrast on hardware, is new. Characters or symbols required for use, and unlabelled operable parts that are not tactilely discernible, have to contrast light on dark or dark on light. The note points at a Michelson contrast of at least 0,7 for characters and 0,4 for operating elements.
• Annex A gains a clause A.2 whose tables are organised by what the ICT is rather than by directive. Table A.4 is "Where ICT is, or includes, hardware", Table A.5 is "All ICT". For a terminal that pair is the nearest thing to a scoping worksheet the standard has published.

Build against V4.1.1 if you are specifying hardware now. Report against V3.2.1 until the citation lands.

Frequently asked questions

Does EN 301 549 apply to hardware?

Yes. Clause 8 is the hardware clause, and clause 8.1.1 also pulls in the generic requirements of clause 5. It covers connection ports, speech output volume, magnetic coupling for hearing aids, reach ranges for stationary ICT, tactile keypad markings and the force needed to operate a control.

What is closed functionality in EN 301 549?

Functionality a user cannot reach with their own assistive technology, by design or in practice. Clause 5.1 covers it. Clause 5.1.2.1 says closed ICT has to meet clauses 5.2 to 13 as applicable, with clause 5.1 supplying the built-in substitutes such as audio output of visual information and operation without a keyboard interface.

Do the EN 301 549 hardware clauses apply to my website?

No. Clauses 5 to 8 are self-scoping and open with conditions like "where ICT is, or includes, hardware". A website with no hardware attached answers clause 9, plus clause 12 on documentation and support services.

Can a scanner check EN 301 549 clauses 5 to 8?

No. Annex C sets the conformance procedure for each requirement, and those procedures are inspection, measurement or functional testing by a person. Automated tools identify roughly 30% to 57% of issues overall, and these clauses are largely physical measurements no scanner can take.

Is EN 301 549 V4.1.1 in force?

It is published but not yet cited in the Official Journal, so V3.2.1 remains the version that carries the presumption of conformity under the Web Accessibility Directive.

Start where the standard is machine-testable

Clauses 5 to 8 need a person with measuring tools. Clause 9 does not, and it is where the machine-detectable failures in a mixed product sit: the web app behind the kiosk, the account pages beside the terminal, the support site clause 12 points at. Run a free scan on those, fix what comes back with a selector attached, then spend the audit budget on the physical clauses where no tool can help. The EN 301 549 checklist has the clause list if you want it open while you scope the work.

Pavel Charkasau, founder, wcagc.com. Last updated 11 September 2026.

Sources

• EN 301 549 V3.2.1 (2021-03), ETSI — the fourteen-clause structure and the clause 5 to 13 scoping statement; clauses 5.1 to 5.9 including 5.1.4 text enlargement and the 5.7 and 5.8 timings; clause 6.1 audio bandwidth; clause 7 captions and audio description; clauses 8.1.2, 8.2.1, 8.2.2, 8.3.2, 8.4.1, 8.4.2.2, 8.4.3 and 8.5; Annex C conformance procedures and assessment types. Accessed 11 September 2026.
• EN 301 549 V4.1.1 (2026-09), ETSI — adoption on 24 August 2026 and the national transposition dates; the renamed clause 6 and new 6.7 total conversation; the clause 8.3 Set 1 and Set 2 split and the 800 mm display rule at 8.3.2; the new 8.8 contrast on hardware; clause A.2 Tables A.1 to A.5; Annex ZB and the EAA product scope it reproduces. Accessed 11 September 2026.
• Directive (EU) 2019/882, EUR-Lex — the European Accessibility Act, Article 2(1) product scope covering self-service terminals, consumer terminal equipment and e-readers. Accessed 11 September 2026.
• Commission Implementing Decision (EU) 2021/1339, EUR-Lex — amends Decision (EU) 2018/2048 to cite EN 301 549 V3.2.1 in the Official Journal for Directive (EU) 2016/2102. Accessed 11 September 2026.
• Automated testing identifies 57% of accessibility issues, Deque — automated coverage measured across more than 2,000 audits. Accessed 11 September 2026.