EN 301 549 and WCAG: how the two standards relate
EN 301 549 is the standard European accessibility law points at. For the web it is largely WCAG with a different numbering scheme — but the numbering is what a regulator expects to see cited.
The mapping, concretely
For web content the relationship is mechanical. Chapter 9 of EN 301 549 mirrors WCAG numbering with a 9. prefix:
| WCAG success criterion | EN 301 549 clause | Level |
|---|---|---|
| 1.1.1 Non-text Content | 9.1.1.1 | A |
| 1.4.3 Contrast (Minimum) | 9.1.4.3 | AA |
| 2.4.7 Focus Visible | 9.2.4.7 | AA |
| 4.1.2 Name, Role, Value | 9.4.1.2 | A |
That is the whole trick for the web. It looks trivial written down, and it is still the step most often skipped: statements routinely cite WCAG numbers alone, which leaves the reader to do the translation into the scheme the law actually references.
What EN 301 549 covers that WCAG does not
The standard is considerably wider than web content. Its other chapters cover generic requirements and hardware (chapters 5 to 8), non-web documents (10), software (11), documentation and support services (12), and relay and emergency services (13).
If your service is a website or a web application, chapter 9 is the relevant part and WCAG conformance carries most of the weight. If you ship a mobile app, a desktop application, a kiosk or PDFs, the other chapters apply too and WCAG alone will not cover the obligation.
Pin the version
Standards move, and the set of criteria moves with them. A statement that says "conforms to EN 301 549" without a version is ambiguous the moment a revision publishes, and it will be read against whichever version the reader assumes.
Record the exact versions you assessed against. This tool writes both into every artifact and into its conformance baseline, so the standard used is part of the record rather than an assumption. Adding a new standard version to the tool is a data change, not a code change — the mapping tables are YAML.
Sources
- ETSI — EN 301 549 published versions
- WCAG 2.1 and WCAG 2.2 (W3C Recommendations)
- W3C — what is new in WCAG 2.2
Common questions
Is EN 301 549 the same as WCAG?
Not the same, but for web content it incorporates WCAG directly. Chapter 9 of EN 301 549 covers web content and its clauses correspond one-to-one with WCAG success criteria at levels A and AA: clause 9.1.4.3 is WCAG 1.4.3 Contrast (Minimum). The standard is broader than WCAG, adding chapters for hardware, software, documentation and support services that have no WCAG equivalent.
Which version applies?
EN 301 549 v3.2.1 is the version currently harmonised, and it incorporates WCAG 2.1 at level AA. A revision incorporating WCAG 2.2 is expected. Because a version change alters which criteria exist, pin the version your statement was assessed against and record it in the document rather than leaving it implicit.
Should an accessibility statement cite WCAG or EN 301 549?
Both, ideally. European law refers to the harmonised standard, so an EN 301 549 clause is the reference a market surveillance authority expects. WCAG numbers are what developers and testing tools use. Citing the pair — "WCAG 1.4.3, EN 301 549 clause 9.1.4.3" — means both audiences can follow the same finding without translation.
What changes with WCAG 2.2?
WCAG 2.2 removes 4.1.1 Parsing and adds six A and AA criteria: 2.4.11 Focus Not Obscured (Minimum), 2.5.7 Dragging Movements, 2.5.8 Target Size (Minimum), 3.2.6 Consistent Help, 3.3.7 Redundant Entry and 3.3.8 Accessible Authentication (Minimum). A statement assessed against 2.1 does not automatically hold against 2.2, because the set of criteria differs.