EN 301 549 is the harmonised European accessibility standard that public-sector procurement across the EU cites by reference. Version 3.2.1 — published in March 2024 — is the edition that implements the European Accessibility Act (Directive 2019/882) which became enforceable on June 28, 2025. If you sell digital products to EU public buyers or to private companies obligated under the EAA, EN 301 549 v3.2.1 is the reference you will be audited against.
The structure of the standard (15 minutes to orient)
- Clauses 4-5: general guidance, scope, terminology.
- Clause 6: ICT that acts as a communication tool (telephony, real-time text, video).
- Clause 7: ICT with video capabilities (captions, audio description, media controls).
- Clause 8: hardware (keys, input mechanisms, haptic feedback, biometric identification).
- Clause 9: web — this is where WCAG 2.1 Level A and AA are incorporated by reference, with every success criterion added as a mandatory requirement.
- Clause 10: non-web documents (PDFs, Word docs, etc.) — a parallel set of requirements.
- Clause 11: non-web software (desktop apps, mobile apps).
- Clause 12: documentation and support services.
- Clause 13: additional ICT requirements for communication with emergency services.
- Annexes A-E: relation to the mandate and to Directive (EU) 2016/2102.
What version 3.2.1 added vs 3.1.1
The delta is small in volume but material in scope for procurement teams:
- WCAG 2.2 alignment pending. v3.2.1 still references WCAG 2.1 AA as the normative web standard. The EU standardisation bodies (CEN, CENELEC, ETSI) have signalled that a subsequent revision will align with WCAG 2.2. Contracts signed in 2026 should keep this upgrade path in mind; AccessiScan ships WCAG 2.2 support today so buyers do not carry the risk.
- Revised document testing clauses (10.x). Non-web documents now have clearer expectations around structural tags, alternate text for images, and table markup.
- Evidence and procurement language. Annex A was updated so that procuring bodies can reference "functional performance statements" — a test-what-the-user-can-actually-do framing — in addition to success-criterion compliance.
What EAA enforcement looks like since June 28 2025
The EAA is a directive, so each EU member state has its own implementing law and its own supervisory body. The common structure:
- Covered products and services include banking (except B2B-only), e-commerce, e-books and e-reading software, passenger transport ticketing and boarding, and emergency communications access.
- Micro-enterprises (fewer than 10 employees AND annual turnover under €2M) are exempt from services obligations. Most SaaS companies exit this exemption quickly.
- Penalties range by member state but are generally in the €50,000-€300,000 range per violation with cumulative caps.
- Market surveillance authorities can require conformity evidence — typically an EN 301 549 Conformance Report — on demand.
The EN 301 549 Conformance Report vs VPAT 2.5
A VPAT 2.5 is the US-origin template originally built for Section 508 / WCAG reporting. Both documents can conform the same system — they are just different framings. Differences in practice:
| Aspect | VPAT 2.5 | EN 301 549 Conformance Report |
|---|---|---|
| Legal reference | Section 508 Refresh; ADA Title II/III | Directive (EU) 2019/882 (EAA); Directive 2016/2102 |
| Normative standard cited | WCAG 2.1 A + AA + Section 508 Chapters 4-7 | Clauses 5-13 of EN 301 549 v3.2.1 |
| Conformance statements | Supports / Partially Supports / Does Not Support / Not Applicable / Not Evaluated | Identical five-level scale |
| Recommended evidence | Automated + manual + assistive-technology testing | Same, plus explicit "functional performance statements" |
Because the scales align, a VPAT 2.5 generated today can usually be reframed as an EN 301 549 Conformance Report with section-header changes and a references update. AccessiScan supports both framings on its Pro tier via a single ?standard=en-301-549 parameter on the export endpoint.
Practical compliance pattern for a SaaS selling into the EU
- Run an automated scan of the in-product pages + marketing site against WCAG 2.1 AA + 2.2 additions. This handles Clause 9.
- Run an accessibility-tagged PDF validator over every customer-facing PDF template (invoices, terms, onboarding guides). This handles Clause 10.
- Test the native mobile app (if any) against WCAG 2.1 AA applied per-platform. This handles Clause 11.
- Produce a one-page "accessibility statement" posted at
/accessibilitynaming the conformance level, known limitations, contact, and feedback procedure. This is both a member state requirement and a Clause 12 obligation. - Keep the conformance report version-controlled and update on every release that touches UI.
How AccessiScan helps
AccessiScan's Pro tier produces an EN 301 549 Conformance Report with per-criterion remarks and automated scan evidence, plus the VPAT 2.5 equivalent if your procurement pipeline needs both. The Business tier adds continuous monitoring so the evidence is current when an authority asks. Start with a free scan to see a sample conformance report generated from your own URL.
References
- ETSI EN 301 549 V3.2.1 (2024-03)
- Directive (EU) 2019/882 of 17 April 2019 (European Accessibility Act)
- Directive (EU) 2016/2102 on the accessibility of websites and mobile applications of public sector bodies