EN 301 549 (harmonised standard for ICT accessibility)

EN 301 549 is the European standard for accessible ICT: clause 9 web, 10 documents, 11 software.

What is EN 301 549?

EN 301 549 is a European standard that sets functional accessibility requirements for ICT products and services. For each requirement it describes test procedures and an evaluation methodology; it addresses both providers and procurers (clause 1). It was produced by ETSI Technical Committee Human Factors and the eAccessibility Joint Working Group of CEN, CENELEC and ETSI (Foreword). Version V3.2.1 was adopted on 10 March 2021 and builds on V2.1.2 (08-2018).

According to its Introduction, the standard reflects the content of the W3C Recommendation WCAG 2.1. Three clauses are central for websites and documents:

Annex A maps the requirements to Directive (EU) 2016/2102. Table A.1 covers web pages and documents, including downloadable forms; Table A.2 covers mobile applications. Live captions (9.1.2.4, 10.1.2.4, 11.1.2.4) are not listed there, because the Directive does not apply to live time-based media (Annex A, note 4).

Legal basis and references

The legal acts reviewed link a presumption of conformity to harmonised standards whose references are published in the Official Journal of the EU. Of the three legal acts reviewed here, only Directive (EU) 2016/2102 names EN 301 549 expressly (Art. 6 and recitals 37, 42 and 54), and only in version V1.1.2 (2015-04).

EU

Under Art. 4 of Directive (EU) 2016/2102, Member States ensure that public sector bodies make their websites and mobile applications perceivable, operable, understandable and robust. Under Art. 6(1), conformity is presumed where content meets harmonised standards whose references are published in the Official Journal. Where no references have been published, EN 301 549 V1.1.2 (2015-04) is the benchmark for the presumption for website content (Art. 6(3)). Art. 6(4) empowers the Commission to update that reference by delegated acts to a more recent version of the standard. According to Annex A of the standard, meeting the clauses listed in Tables A.1 and A.2 confers the presumption once the standard is cited in the Official Journal under the Directive. The presumption remains valid only as long as that reference is maintained in the list in the Official Journal.

Germany

Under § 3 Abs. 2 BITV 2.0, the requirements are presumed to be met where services, applications and offerings meet harmonised standards that have been named in the Official Journal of the EU. Where standards do not cover a requirement, it must be made accessible according to the state of the art (§ 3 Abs. 3). BITV 2.0 does not name EN 301 549 expressly. Integrated content such as documents forms part of websites (§ 2a Abs. 1).

Austria

§ 3 Abs. 2 WZG likewise links the presumption to harmonised standards whose references have been published in the Official Journal. The body responsible under § 5 must publish these references on its website (§ 3 Abs. 3). The WZG applies to websites and mobile applications of the federal government and federally affiliated institutions (§ 2 Abs. 1). The federal states (Länder) and municipalities are covered by the state laws. The WZG does not name EN 301 549 expressly either.

Practical example

For a downloadable PDF created from Word or PowerPoint, clause 10 is the benchmark. Example: a federal authority in Germany or a federal body in Austria publishes an application form as a PDF on its website. Check, among other things:

• 10.1.1.1 Non-text content: the clause requires WCAG 2.1 Success Criterion 1.1.1. Graphics and other non-text content therefore need a text alternative that serves the equivalent purpose, such as alternative text; the criterion lists exceptions.
• 10.1.3.1 Info and relationships: structure such as headings, lists and tables must be programmatically determinable or available in text (WCAG 2.1 Success Criterion 1.3.1). According to the note to the clause, it is best practice to map non-standard structure types to standard ones.
• 10.1.3.2 Meaningful sequence: where the sequence affects the meaning, a correct reading order must be programmatically determinable (WCAG 2.1 Success Criterion 1.3.2).
• Protected files: clause 10 also applies to signed, encrypted, password-protected or watermarked documents when they are presented to the user (clause 10.0, note 7).

A PowerPoint presentation offered for download also falls under clause 10. How the standard relates to WCAG and PDF/UA is explained in PDF/UA, WCAG and EN 301 549 for documents. If you prefer not to check files yourself, you can have accessible documents prepared. This entry does not constitute legal advice.

See also

• WCAG 2.1 (Web Content Accessibility Guidelines)
• PDF/UA (ISO 14289)
• BITV 2.0 (German Barrier-free Information Technology Ordinance)
• WZG (Austrian Web Accessibility Act)