While waiting for EN 301 549 – our top tips

For several years now, EN 301 549 has been the key European standard for digital accessibility. The standard is used to specify accessibility requirements for digital accessibility in the Web Accessibility Directive (WAD) and will also play a key role in the European Accessibility Act (EAA).

The EAA has been in force for almost a year now, but the updated version of EN 301 549 is not yet finalised. This creates some confusion as to what actually applies and when.

The accessibility requirements are set out in the Act

This is by no means an ideal situation. Regardless of one’s perspective, all standards should have been published and finalised when the Act was applicable in the EU member states. Arguing over whose fault it is does not seem particularly meaningful; it is better to find constructive solutions.

First and foremost: the current version of the EN 301 549 (v. 3.2.1) still applies to all organisations covered by WAD.

The following applies to organisations covered by the EAA:

• Annex A of the EAA lists the accessibility requirements.
• Unlike the WAD, which refers directly to EN 301 549, the accessibility requirements in this case are set out in the law itself.

EAA Annex A contains:

• general accessibility requirements for all products covered,
• general accessibility requirements for all services covered,
• specific accessibility requirements for certain products, and
• specific accessibility requirements for certain services.

In addition to the accessibility requirements, there are a large number of formal requirements concerning documentation, reporting and similar matters, which differ slightly between manufacturers, importers, distributors, etc.

Rather than focusing on what is missing (an updated version of the standard), organisations covered by the EAA should work on the basis of the requirements that have been in place since 2019 – namely those set out in the EAA.

It is, in fact, the requirements of the law that apply. The standard will hopefully be of great help to anyone wishing to comply, but the use of European standards is voluntary. If you can present a way of meeting the requirements of the law, that is fine, but you must then describe how. In this way, the legislation allows for innovation.

What does the update contain?

Although the updated version of EN 301 549 is not yet finalised, there are a few things we already know for certain.

• Requirements referring to the Web Content Accessibility Guidelines (WCAG) have been updated to WCAG 2.2 (the current version refers to WCAG 2.1).
• Requirements regarding real-time text and communication have been amended and clarified.
• Requirements regarding hardware have been amended and clarified.
• In general, several parts of the standard have been restructured to better align with the requirements of the EAA. Among other things, there are new annexes describing the requirements applicable to the WAD and the EAA respectively.

The revision of EN 301 549 is in its final stages; the final standard will most probably be published in the early autumn. It is only once the European Commission has approved the document and the standard has been published in the Official Journal that it will formally serve as a presumed conformance to the EAA.

If you would like to get an idea of the direction the new version of EN 301 549 is taking, you can read a draft here. Please note that this is a draft, not a normative document.

EN 301 549 DRAFT version 4.2.1 – PLEASE NOTE: this document is not the final version of the standard, opens in a new window