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EN 301 549WCAGEAA

EN 301 549 vs WCAG: the exact relationship

EN 301 549 vs WCAG isn't a choice. WCAG 2.1 AA is the web-content requirement inside EN 301 549, which then goes further. How the two map.

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Pavel Charkasau

"EN 301 549 vs WCAG" reads like a choice between two standards, but it isn't one. WCAG is a technical specification from the World Wide Web Consortium (W3C) that defines, in testable success criteria, what accessible web content is. EN 301 549 is the European standard for the accessibility of ICT, and for web content it does not reinvent anything: it adopts WCAG 2.1 Level AA wholesale in its Chapter 9. So if your website meets WCAG 2.1 AA, it meets the web-content part of EN 301 549 by definition. The real difference is scope. EN 301 549 is the larger container. It also sets requirements for hardware, non-web software, documents, and features like real-time text that WCAG never touches. And it is the standard the European Accessibility Act relies on for a presumption of conformity, which is what gives it legal weight in the EU. This guide maps the two clause by clause, shows which WCAG version applies today, and explains where meeting WCAG stops short of the full standard.

Is EN 301 549 the same as WCAG?

No, but they overlap almost completely on the web. Think of it as a container and its contents. WCAG is the content: a focused set of success criteria for web pages and web apps. EN 301 549 is the container: a broader European standard for information and communication technology that pulls WCAG in for the web and then adds requirements WCAG was never designed to cover.

The practical consequence is that the two are inseparable for a website but not interchangeable for a product. If your accessibility work only ever touches web pages, "meeting WCAG 2.1 AA" and "meeting the web clauses of EN 301 549" describe the same task. The moment your product includes a kiosk, a mobile app, a phone, or a PDF, EN 301 549 asks for things WCAG cannot, because those things sit outside web content.

What is WCAG, in plain terms?

WCAG stands for the Web Content Accessibility Guidelines, published by the W3C's Web Accessibility Initiative (W3C). It is built from success criteria, each one a specific and checkable requirement, sorted into three conformance levels: A is the floor, AA is the level almost every law and contract asks for, and AAA is the strictest and rarely required in full.

Three versions are in active use. WCAG 2.0 dates from 2008. WCAG 2.1 arrived in 2018 and added criteria for mobile, low vision, and cognitive accessibility. WCAG 2.2 became a W3C Recommendation on 5 October 2023, adding nine success criteria on top of 2.1 (W3C). WCAG on its own carries no legal obligation. It is a technical document that laws and standards choose to reference, which is exactly what EN 301 549 does.

What is EN 301 549?

EN 301 549 is the harmonised European standard for the accessibility of ICT products and services. Three European standards bodies maintain it jointly: CEN, CENELEC, and ETSI. Where WCAG covers only web content, EN 301 549 covers a much wider surface, including hardware, non-web software, native mobile apps, documentation, biometrics, and telecoms features such as real-time text and two-way voice communication (ETSI EN 301 549 v3.2.1).

The version that matters legally today is EN 301 549 v3.2.1, published in March 2021. It is the one referenced for the European Accessibility Act and for the earlier Web Accessibility Directive that governs public sector sites. Its structure is chapter by chapter: Chapter 5 for generic requirements, Chapter 9 for web content, Chapter 10 for non-web documents, Chapter 11 for non-web software, and so on. Chapter 9 is where WCAG lives.

How does EN 301 549 incorporate WCAG?

Directly, and with almost no translation. In EN 301 549 v3.2.1, clauses 9.1 through 9.4 hold the WCAG 2.1 success criteria at Levels A and AA, renumbered with a "9." prefix. Clause 9.1.4.3 is WCAG 1.4.3 Contrast (Minimum); clause 9.2.4.7 is WCAG 2.4.7 Focus Visible. The mapping is one to one. The standard then states in clause 9.6 that meeting the relevant web clauses is equivalent to conforming to WCAG 2.1 Level AA (ETSI EN 301 549 v3.2.1).

That equivalence runs both ways for the web. Conform to WCAG 2.1 AA and you satisfy Chapter 9. Satisfy Chapter 9 and you have, by definition, conformed to WCAG 2.1 AA. This is why an auditor testing a website can report against either label and mean the same set of checks. It is also why the numbering looks familiar to anyone who already works in WCAG: the standard borrows the criteria rather than rewriting them.

What EN 301 549 adds around that borrowed chapter is the rest of the ICT picture. Non-web software has its own clauses that echo WCAG "where the software provides a user interface." Documents get Chapter 10. Hardware gets Chapters 5 and 8. None of that is web content, so none of it appears in WCAG at all.

Which WCAG version does EN 301 549 require?

Right now, WCAG 2.1 Level AA, because that is the version frozen into EN 301 549 v3.2.1. Teams often assume the newest WCAG is automatically the legal bar. It isn't. The law tracks the standard, and the standard tracks a specific version of WCAG. So even though WCAG 2.2 has been a Recommendation since 2023, and was approved as an ISO/IEC standard in 2025 (W3C), the working European requirement stays at 2.1 AA until the standard is updated.

That update is under way. A draft, EN 301 549 v4.1.0, was released for public comment in November 2025, and the final v4.1.1 is expected to bring WCAG 2.2 into Chapters 9, 10, and 11 and to add new annexes mapping the standard to the EAA and the Web Accessibility Directive (ETSI EN 301 549 v4.1.0 draft). Until that version is cited in the EU's Official Journal, v3.2.1 and WCAG 2.1 AA remain the reference. The sensible planning position is to build to 2.1 AA today while designing with 2.2's additions in mind, so the eventual shift is a small step. Our WCAG checklist tracks against 2.1 AA and flags where 2.2 adds something new.

If I meet WCAG 2.1 AA, do I meet EN 301 549?

For a website that is nothing but web content, yes, you meet the web clauses. For most real products, WCAG 2.1 AA is necessary but not sufficient. Two gaps usually remain.

The first is scope. If your product reaches beyond the browser, into a native app, a self-service terminal, a PDF, or a hardware device, EN 301 549 has clauses that WCAG does not, and those apply no matter how clean your website is. A perfectly accessible checkout page says nothing about whether your in-store kiosk meets Chapter 8.

The second is proof. "Meeting WCAG" is harder to demonstrate than it sounds, because automated tools only see 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.

No scanner, and no overlay widget, can confirm WCAG conformance 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 honest route is to fix what a scanner finds, review the rest by hand, and record where you stand, ideally in a published accessibility statement.

Frequently asked questions

Is EN 301 549 the same as WCAG?

No. WCAG is a W3C specification for accessible web content. EN 301 549 is a broader European standard for ICT accessibility that adopts WCAG 2.1 AA for web content in its Chapter 9 and adds requirements for hardware, software, and documents that WCAG does not cover.

Does EN 301 549 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 current referenced standard. A draft v4.1.0 went out for comment in November 2025, and the final v4.1.1 is expected to bring in WCAG 2.2, but 2.1 AA is the working bar today.

If my website meets WCAG 2.1 AA, does it meet EN 301 549?

For the web clauses, yes, because Chapter 9 of EN 301 549 is WCAG 2.1 AA. But EN 301 549 also covers non-web software, hardware, and documents, so a product that is more than a website has requirements WCAG never addresses.

How do the clause numbers map?

One to one. EN 301 549 clause 9.X.Y.Z is WCAG success criterion X.Y.Z with a "9." prefix. Clause 9.1.4.3, for example, is WCAG 1.4.3 Contrast (Minimum).

Is EN 301 549 legally binding?

Not by itself, but it is the harmonised standard the European Accessibility Act and the Web Accessibility Directive rely on. Meeting it gives a presumption of conformity with those laws, which is where its legal force comes from.

See where your site stands against WCAG 2.1 AA

Since Chapter 9 of EN 301 549 is WCAG 2.1 AA, the useful first move is to measure your website against that bar. Run a free scan to surface the machine-detectable issues on your key pages, then work through the manual checks a scanner cannot judge. You will have a real baseline for the web part of EN 301 549, and the evidence to write an honest accessibility statement instead of a guess.

Pavel Charkasau, founder, wcagc.com. Last updated 4 July 2026.

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