EN 301 549 explained

EN 301 549 is the European standard for accessible technology. For a website, one part of it matters: clause 9, which is WCAG 2.1 Level AA. If your site meets WCAG 2.1 AA, it meets clause 9. The rest of the standard is about hardware, documents, and support services.

What the standard is

EN 301 549 is published by ETSI, CEN and CENELEC, the European standards bodies. The current version is v3.2.1, from March 2021. It covers websites, software, documents, hardware, and the support that goes with them. Clause 9 is the web clause.

Clause 9 does not invent its own rules. It adopts the Web Content Accessibility Guidelines (WCAG) 2.1, Level A and Level AA, which is the international standard most teams have already heard of. That is the whole relationship: clause 9 is WCAG 2.1 AA, restated in European form.

How it relates to the European Accessibility Act

The Act, Directive (EU) 2019/882, has applied since 28 June 2025. It sets out what accessibility has to achieve, in general terms. It does not point at a technical standard.

This is the part most articles get wrong, so it is worth being exact. No version of EN 301 549 has been cited in the Official Journal under the Act. Meeting the standard therefore gives you no automatic legal presumption of compliance today. What it gives you is the best available evidence that you took the requirement seriously, assessed against the criteria your regulator is most likely to use.

That is expected to change. Draft v4.1.0 is at the formal voting stage, and v4.1.1 is expected to be cited around October 2026. It adds an annex mapping the standard to the Act, and it moves clause 9 up to WCAG 2.2 Level AA. Six new criteria come with that: focus appearance, dragging movements, target size, consistent help, redundant entry, and accessible authentication.

Who the Act actually covers

Less broadly than the phrase "any business selling into the EU" suggests. Three limits matter:

• It is a list of services, not the whole web. Article 2 names them: e-commerce, consumer banking, electronic communications, access to audiovisual media services, parts of passenger transport, and e-books. E-commerce is the wide one and catches most commercial sites. A brochure site that concludes no transaction online is not automatically in scope.
• It covers consumers, not all customers. A business selling only to other businesses is generally outside it, as are internal staff systems.
• Microenterprises providing services are exempt. Fewer than 10 people, and turnover or balance sheet total no more than €2 million. This is a statutory exemption, not something you have to argue for.

Where you are based does not matter. If you sell to consumers in the EU, the Act reaches you.

What the penalties actually are

There is no EU-wide fine. Article 30 tells each member state to set penalties that are effective, proportionate and dissuasive, and the results vary by more than an order of magnitude.

Quoted ranges starting at six figures are usually the top of one country's scale presented as the European norm. The realistic first consequence is not a fine at all. It is a complaint, or a customer asking for your accessibility statement and not getting one.

What to check first

Most failures on a real site come from a short list, and most of that list is machine-detectable:

• Images without text alternatives. Every image that carries meaning needs alt text. Decorative ones need empty alt text, not none.
• Text contrast. 4.5:1 for body text, 3:1 for large text. Grey-on-white body copy is the most common failure there is.
• Form fields without labels. A placeholder is not a label. This one blocks people from buying, so it costs money as well as compliance.
• Keyboard access. Everything clickable must be reachable with Tab and usable with Enter or Space, with a visible focus ring.
• Heading structure. One h1, then h2 and h3 in order. Screen reader users navigate by heading the way sighted users skim.
• Language and page title. A lang attribute and a unique, descriptive title on every page.

What an automated test can and cannot tell you

An automated test finds a minority of accessibility problems. How big a minority is genuinely contested. About 30% of WCAG success criteria can be meaningfully automated at all. Deque, who make the engine most scanners use and so have an interest in the answer, report that automation catches 57% of individual issues found on first-time audits.

So a clean automated result means nothing machine-detectable was found. It never means compliant. What automation is very good at is the concrete, unarguable things: missing alt text, contrast, form labels, ARIA misuse, heading structure. That is also most of what an inspector checks first.

What it cannot judge: whether your alt text describes the right thing, whether your page makes sense read aloud in order, whether a video has accurate captions, whether an error message tells someone how to fix the problem. Those need a person.

Check a page now

This site runs the automated part free. Paste a URL and it opens the page in a real browser, tests it, and maps every failure to the clause of EN 301 549 it puts at risk.

Scan a page against clause 9

Sources

• Directive (EU) 2019/882 (the European Accessibility Act), Articles 2, 4(5), 14 and 30.
• EN 301 549 v3.2.1 (2021-03), clause 9. Harmonised by Commission Implementing Decision (EU) 2021/1339, under the Web Accessibility Directive.
• Draft EN 301 549 v4.1.0 (2025-11), published by ETSI for public enquiry.
• WCAG 2.1 and WCAG 2.2, W3C Recommendations.
• Deque, published figures on automated coverage of first-time audit issues.

Checked 2026-07-27. This page describes a law and a standard. It is not legal advice.

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