For those who don’t like to read: The European Accessibility Act (EAA) obliges private companies to implement EN 301 549. EN 301 549 refers to WCAG (2.1). Websites and online shops generally only need to implement the WCAG guidelines (from Chapter 9 of the EN standard). Those developing more complex software or web apps must also comply with other requirements of the standard.
And now everything in detail:
What is EN 301 549?
“EN 301 549, entitled ‘Accessibility requirements for ICT products and services’, is a European standard for digital accessibility. It defines requirements for the accessibility of information and communication technology in the public sector and is considered a binding standard.”
From June 2025, websites and apps are legally required to be accessible across the EU. This is regulated by the European Accessibility Act (EAA). The EAA establishes accessibility rules across all EU states for the private sector. The technical requirements are based on the EN 301 549, which is also largely based on the Web Content Accessibility Guidelines.
Where can I find the EN 301 549?
You can download the standard in English here.
This PDF is the official published document of the EN 301 549 V3.2.1 standard, released by ETSI. Organizations can reference this document and the standards within it for compliance with the EU digital accessibility law.
What do I need to do to become accessible according to EN 301 549?
It depends on what kind of digital product you have. If you have a website or an online shop, Chapter 9 is usually relevant.
Chapter 9 contains the following content and refers exclusively to the web:
- 9 Web
- 9.0 General (informative)
- 9.1 Perceivable
- 9.1.1 Text alternatives
- 9.1.2 Time-based media
- 9.1.3 Adaptable
- 9.1.4 Distinguishable
- 9.2 Operable
- 9.2.1 Keyboard operable
- 9.2.2 Sufficient time
- 9.2.3 Seizures and physical reactions
- 9.2.4 Navigable
- 9.2.5 Input Modes
- 9.3 Understandable
- 9.3.1 Readable
- 9.3.2 Predictable
- 9.3.3 Input Support
- 9.4 Robust
- 9.4.1 Compatible
- 9.5 WCAG 2.1 Level AAA Success Criteria
- 9.6 WCAG Conformity Requirements
As you can see, the standard refers to the WCAG – but we’ll talk about that in the next part.
In addition to the requirements in Chapter 9, other parts of the standard may also apply to you. However, this is usually only the case if you are developing desktop software. But nowadays, there are also complex web applications that run entirely in the browser, like the design tool Figma and image-editing programs like Photoshop. Such complex software is very likely to be affected by other parts of the standard.
Further chapters of the EN standard that concern software:
- General requirements (Chapter 5)
- Requirements for technologies with two-way voice communication (Chapter 6)
- Requirements for embedded video players (Chapter 7)
- Requirements regarding user-defined settings and authoring tools (Chapter 11)
- Documentation and Support Requirements (Chapter 12)
For those seeking a legally sound and precise list of which test steps are relevant for which components, the Federal Monitoring Agency has created something: the guideline for Accessible design of user interface elements
This guide describes, for a wide variety of user interface elements, which EN standard criteria must be implemented to make the components accessible. You will also notice that many “checks” refer to section 9. X and thus to the WCAG criteria.
The relationship between WCAG and EN 301 549
If I want to be accessible, don’t I just have to follow the WCAG guidelines?
Unfortunately, it’s not that simple! As we’ve already learned, Chapter 9 of EN 301 549 lists the relevant guidelines for websites. These guidelines refer to WCAG, specifically WCAG 2.1. For websites or online shops, it’s usually sufficient to adhere to the WCAG guidelines. Many points of the standard simply do not apply to a website or online shop.
So what does this mean for the private sector?
Your website, (web) app, online shop, or software must meet the requirements of EN 301 459 from 28.6.2025.
Your digital product must therefore meet at least the WCAG 2.1 requirements. Depending on the scope of your digital product, you may need to meet further requirements, for example, if you enable two-way voice communication (video telephony) in your software.
Attention: Who is liable for what?
Many people won’t make their websites accessible themselves. Most online shops or large websites rely on agencies to build them. Therefore, the question arises: Who is to blame if things go wrong?
The website creator is responsible for accessibility.
Depending on the terms of the contract with service providers, they can be held liable for non-compliance with EN 301 549. If an agency has assured the client that it will create a website compliant with EN 301 549, it can also be held accountable.
However, some points here could also lead to disputes. To quote Oliver Haake-Klink:
“It’s impossible to have 100% control over editorial work. Therefore, according to the legal notice, the website operator is and remains responsible for its condition. That’s my understanding of the law!”
Website operators are therefore not off the hook. Especially if a website is further modified, they are responsible for ensuring accessibility. And the operators are also liable for editorial content not created by the agency.
Integration of third-party software.
Operators are responsible for the accessibility of their online presence, regardless of whether they programmed a function themselves or integrated it from a third-party provider.
You should look for third-party providers whose products are accessible. If no such providers exist for a specific need, you should ideally document the accessibility issues in the “Accessibility Statement” and link to the providers’ websites.
If possible, provide an accessible alternative version of the information. For example, a map view could also be displayed using a list of addresses.
Conclusion and checklist regarding the BFSG and EN 301 549
This clarifies what private companies will need to adhere to in the future and which rules and standards are relevant for you. For those operating a standard website, many of the EN 301 549 guidelines are not applicable. Therefore, for most, it’s primarily important to comply with the WCAG criteria. We’ve summarized these criteria for you here in an easy-to-understand overview: WCAG Criteria.
Here’s a short list to conclude:
- Exceptions apply to micro-enterprises (fewer than 10 employees and less than 2 million in revenue).
- Only digital business transactions are affected (this also includes reservation and booking tools).
- The applicable requirements are set out in EN 301 549 (WCAG 2.1 + a little more)
