EN 301 549: Accessibility requirements for ICT products and services

EN 301 549 “Accessibility requirements for ICT products and services” is a comprehensive European Standard that defines how information and communication technology (ICT) products and services should be designed to enable their use by people with disabilities. Currently at version V3.2.1 (published March 2021), the standard is jointly produced by three European standardization organizations: CEN (European Committee for Standardization), CENELEC (European Committee for Electrotechnical Standardization), and ETSI (European Telecommunications Standards Institute).

This standard became the harmonized European Standard for the Web Accessibility Directive on 18 August 2021, providing the technical foundation for digital accessibility compliance across the European Union. EN 301 549 is unique in that it extends web accessibility principles to cover the entire spectrum of ICT products and services, including hardware, telecommunications, non-web documents, and software platforms.

Evolution and Future Development

EN 301 549 has evolved to keep pace with accessibility best practices:

  • V1.1.1 (2014): Initial version based on WCAG 2.0
  • V2.1.2 (2018): Updated to incorporate WCAG 2.1
  • V3.2.1 (March 2021): Current version, harmonized August 2021
  • V4.1.1 (planned 2026): Expected to incorporate WCAG 2.2 and support the European Accessibility Act

Scope and Coverage

Unlike WCAG 2.2, which focuses specifically on web content accessibility, EN 301 549 provides a holistic framework covering all ICT products and services:

ICT Category Coverage (Clause) Key Requirements
Web Content Clause 9 Incorporates WCAG 2.1 Level A and AA in full; applies to websites and web applications
Non-Web Documents Clause 10 PDF, Word documents, ePub, and other electronic documents; applies WCAG2ICT guidance
Software Clause 11 Desktop applications, mobile apps, operating systems; platform-independent requirements
Hardware Clauses 5, 8 Physical controls, displays, tactile indicators, audio jacks; accessibility of devices themselves
Telecommunications Clause 6 Voice, video, messaging services; real-time text (RTT), captions, relay services
Video Capabilities Clause 7 Audio description, captions, sign language; media player accessibility
Support Services Clause 12 Help desks, technical support, training; accessible communication channels

Self-Scoping Concept

A distinctive feature of EN 301 549 is its “self-scoping” approach: many requirements begin with preconditions like “Where ICT provides…” This means requirements only apply when the ICT product or service provides that specific capability, making the standard applicable across diverse ICT contexts while remaining practical to implement.

Structure and Organization

EN 301 549 comprises 14 clauses and 6 annexes:

Key Clauses

Clause 4: Functional Performance Statements Describes the accessibility needs from a user perspective: perception, operation, and understanding. These non-testable statements explain why accessibility matters and provide context for the technical requirements. All functional performance statements are met when the related technical requirements in Clauses 5-13 are satisfied.

Clause 9: Web Content Incorporates WCAG 2.1 Level A and AA in their entirety. This clause makes EN 301 549 = WCAG 2.1 for web content, while extending the standard’s reach to non-web ICT. Organizations compliant with WCAG 2.1 AA automatically meet Clause 9 requirements.

Clause 10: Non-Web Documents Applies WCAG 2.1 success criteria to electronic documents using the WCAG2ICT interpretive guidance. Covers PDFs, word processing documents, spreadsheets, presentations, and ePub files. Requirements address document structure, alternative text, reading order, and accessible forms.

Clause 11: Software Extends accessibility requirements to software including desktop applications, mobile apps, and operating systems. Applies WCAG 2.1 principles beyond web browsers, addressing platform-specific considerations like keyboard navigation, focus management, and assistive technology APIs.

Clause 8: Hardware Specifies physical accessibility requirements: tactile controls that can be operated without gripping or twisting, sufficient spacing between controls, visible and tactile differentiation of controls, and accessible connection points for headphones and assistive listening devices.

Clause 14: Conformance Defines how conformance to EN 301 549 is determined. Uses the testing procedures in Annex C to evaluate whether requirements are met.

Important Annexes

Annex A (normative): Relationship to Web Accessibility Directive Maps EN 301 549 requirements to the specific clauses that must be met for compliance with the Web Accessibility Directive (EU) 2016/2102. Essential for public sector organizations.

Annex B (informative): Functional Performance Statements Mapping Shows how each technical requirement (Clauses 5-13) relates to the functional performance statements in Clause 4, explaining which user needs are addressed by each requirement.

Annex C (normative): Determination of Conformance Provides detailed testing procedures for assessing conformance to each requirement. Specifies preconditions, test methods, and pass/fail criteria for systematic evaluation.

Relationship to WCAG

EN 301 549 incorporates WCAG 2.1 Level A and AA in full and extends these principles to all ICT products and services. This relationship can be understood as:

EN 301 549 = WCAG 2.1 + ICT extensions for hardware, documents, software, and telecommunications

WCAG2ICT Application

For non-web contexts (documents, software), EN 301 549 applies the WCAG2ICT interpretive guidance, which explains how each WCAG success criterion applies beyond web content. For example, WCAG 1.3.1 (Info and Relationships) applies to:

  • Web: Semantic HTML markup
  • Documents: Proper heading structure, lists, and table markup in PDFs
  • Software: Programmatic relationships exposed through platform accessibility APIs

See the WCAG 2.2 standard page for detailed information about the POUR principles (Perceivable, Operable, Understandable, Robust) that form the foundation of both WCAG and EN 301 549.

WCAG POUR Principles in EN 301 549

EN 301 549’s functional performance statements (Clause 4) directly align with the WCAG POUR principles:

  • Perceivable: Users can perceive information through available senses (4.2.1-4.2.5)
  • Operable: Users can operate controls and navigate (4.2.6-4.2.8)
  • Understandable: Users can understand information and operation (4.2.9-4.2.10)
  • Robust: Content works with assistive technologies (4.2.11)

Future WCAG 2.2 Alignment

EN 301 549 V3.2.1 currently incorporates WCAG 2.1, not WCAG 2.2. The planned V4.1.1 (expected 2026) will update to incorporate WCAG 2.2’s nine additional success criteria. Organizations implementing EN 301 549 today may choose to proactively adopt WCAG 2.2 criteria to future-proof their accessibility efforts.

Quality Attributes Required or Emphasized

EN 301 549 directly influences multiple quality attributes essential for accessible, inclusive ICT products and services:

Quality Attribute Relevance in EN 301 549
Accessibility Core focus: ensuring ICT products and services are usable by people with disabilities across web, software, hardware, and telecommunications. Foundation of all EN 301 549 requirements.
Usability Enhanced through requirements for predictable behavior, clear navigation, sufficient time, error prevention and recovery. Universal design principles benefit all users, not just those with disabilities.
Inclusivity Ensures equal access regardless of disability, age, device, or context of use; extends WCAG principles to all ICT products and services, reaching users in diverse situations.
Interaction Capability Supports multiple input methods (keyboard, mouse, touch, voice, switch access); flexible interaction patterns from hardware controls to software interfaces enable diverse user needs.
Operability WCAG POUR principle incorporated from WCAG 2.1: All functionality operable via multiple input methods; hardware controls accessible without complex manipulation; no timing dependencies that exclude users.
Understandability WCAG POUR principle: Clear, readable content; predictable behavior; input assistance across web, software, documents, and hardware. References WCAG 3.1-3.3 extended to all ICT.
Robustness WCAG POUR principle: Compatibility with diverse user agents, assistive technologies, and ICT environments through valid markup, standard APIs, and platform accessibility services. WCAG 4.1 extended.
Compliance Foundation for EU legal compliance: Web Accessibility Directive 2016/2102 (public sector), European Accessibility Act 2019/882 (private sector from June 2025). Harmonized standard with presumption of conformity.
Flexibility Content and interfaces adapt to screen sizes, orientations, zoom levels (up to 200%), color schemes, text spacing without loss of information or functionality. Hardware provides flexible mounting and positioning.
User Error Protection Input validation, error identification, correction suggestions, confirmation mechanisms for critical actions; reversible operations. WCAG 3.3 extended to all ICT contexts including hardware controls.
Interoperability Standard protocols and APIs enable integration with assistive technologies (screen readers, magnifiers, alternative input devices, switch access) across platforms, operating systems, and devices.
Consistency Predictable navigation, identification, and behavior across pages, applications, and ICT products; consistent user interface components. WCAG 3.2 principles applied universally.

References and Resources

Official ETSI/CEN/CENELEC Sources

EU Legislation