Is WCAG Conformance Enough for EAA Compliance?

If your business currently operates in the European Union (EU) or is planning to expand into the EU market, compliance with the European Accessibility Act (EAA) should be a top priority. Enforcement of the EAA is set to begin on June 28, 2025, with fines and penalties being levied on companies that fail to comply with the law’s digital accessibility requirements.

The presumptive standard for EAA compliance is EN 301 549, the harmonized European digital accessibility standard. EN 301 549 closely resembles the Web Content Accessibility Guidelines (WCAG)—in fact, it’s largely based on this global standard. But is WCAG conformance enough for a digital product or service to be compliant with the EAA?

The short answer is no: EN 301 549 includes additional requirements beyond the scope of WCAG. There are also some differences in the way criteria are applied. In this blog, we’ll unpack the relationship between these two standards and how they differ.

The relationship between EN 301 549 and WCAG

EN 301 549 incorporates WCAG as the basis for web and digital content accessibility. The most recent version of the European standard includes the full text of WCAG 2.1 A and AA, and it’s currently being updated to align with WCAG 2.2 A and AA.

Like WCAG, EN 301 549 is grounded in the notion that accessible digital experiences must be perceivable, operable, understandable, and robust (POUR) for users with disabilities. Digital accessibility best practices that support WCAG 2.1 conformance, such as making text alternatives available for images and ensuring that content is navigable via a keyboard, also support conformance with EN 301 549.

However, while WCAG is intended primarily to support the creation of web and mobile content, EN 301 549 addresses accessibility for a broader range of information and communication technology (ICT) products and services. To that end, EN 301 549 goes beyond WCAG by covering additional aspects of ICT accessibility, including requirements for hardware, documentation, mobile apps, and certain features like video players.

Companies that provide ICT products and services covered by the EAA should ensure these offerings meet EN 301 549, plus additional criteria from WCAG 2.2, as a best practice.

We’ll explore the differences between EN 301 549 and WCAG, and their implications for businesses, in more depth in the following sections of this blog.

Key differences between EN 301 549 and WCAG

Now that we’ve covered the relationship between EN 301 549 and WCAG, including how the standards overlap and differ at a high level, let’s take a deeper dive into their main distinctions. EN 301 549 and WCAG are unique from one another in two main aspects: their scope of application, and their alignment with legal frameworks.

Scope of application

As previously discussed, WCAG applies primarily to web and mobile content, such as websites, online documents, and mobile applications. Meanwhile, EN 301 549 applies not only to web-based content but also to other ICT products and services, such as hardware (e.g., ATMs, kiosks, and telecommunications devices), two-way voice communication, video players, authoring tools, and software.

For example, EN 301 549 includes criteria supporting:

• Hardware accessibility: Devices must be physically accessible to users with disabilities, such as offering tactile feedback or adjustable height for kiosks.
• Telecommunications accessibility: Two-way voice communication services must meet accessibility requirements, including providing options for real-time text communication.
• Accessible documentation and support services: User guides, help content, and customer support for ICT must be accessible.
• Interoperability with assistive technologies: ICT products must work seamlessly with assistive devices like screen readers, braille displays, and alternative input devices. (While this is also an objective of WCAG, EN 301 549 aims to support interoperability for a broader range of ICT experiences.)

Ultimately, EN 301 549 offers detailed technical specifications that stretch across the digital realm, promoting accessibility across many aspects of ICT.

Alignment with legal frameworks

Developed by the Worldwide Web Consortium (W3C) as an international standard, WCAG has been integrated into accessibility legislation worldwide. Laws adopting WCAG include Title II of the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act of 1973 in the U.S. and the Accessibility for Ontarians with Disabilities Act (ADA) in Canada.

Meanwhile, EN 301 549 was developed by the European Telecommunications Standards Institute to support compliance with European laws, including the European Union Web Accessibility Directive (WAD) and the EAA.

Moving from WCAG conformance to EAA compliance

If your organization has already achieved WCAG conformance, you’ve made significant progress toward meeting EN 301 549 requirements—and, by extension, complying with the EAA. However, additional steps may be necessary to bridge the gap. Businesses must evaluate their ICT products and services comprehensively, considering all aspects of EN 301 549, including:

• Hardware design and functionality.
• Accessibility of support services, including call centers, and documentation, including physical product manuals.
• Compatibility with assistive technologies across various devices.
• Providing alternative input / output methods for closed functionality software.

For instance, a company that provides an accessible website, in conformance with WCAG 2.1, may still fall short of EN 301 549 conformance if its customer support channels, biometric authentication methods, or embedded video players do not meet the broader accessibility requirements of the European standard.

Beyond EN 301 549: Additional considerations for EAA compliance

Conforming with EN 301 549 is the best way for organizations to demonstrate compliance with the EAA’s functional accessibility requirements. However, beyond meeting these functional requirements, organizations with products or services covered by the EAA should adhere to several other best practices to achieve ongoing compliance with the law:

• Publishing accessibility statements: The EAA requires that organizations publish accessibility statements to their websites. A statement should include the steps an organization has taken to ensure accessibility, the scope and limitations of their accessibility posture, and how they’re satisfying their obligations to maintain accessibility under the EAA.
• Implementing accessibility training: To sustain EAA compliance over time, organizations should implement practical digital accessibility training for their employees.
• Continuously monitoring digital accessibility: Every change made to a digital experience, such as the creation of a new webpage or the addition of a new product feature, can introduce accessibility risks that jeopardize an experience’s EN 301 549 conformance. Continuous monitoring is necessary to ensure that possible barriers are identified and remediated in a timely manner.

Achieve EN 301 549 conformance with a trusted partner

While WCAG conformance is a crucial step toward achieving accessibility, it is not sufficient on its own to demonstrate compliance with the EAA. Businesses offering ICT products within the EAA’s scope will likely need to address additional accessibility criteria outlined in EN 301 549 to meet the law’s requirements. And by adopting a comprehensive strategy for ICT accessibility, organizations can not only avoid penalties but also unlock the benefits of providing an inclusive user experience—expanding their market reach in the EU and beyond.

With more than 25 years of accessibility expertise, Level Access has supported countless organizations across North America, Europe, and other global markets to conform with accessibility standards, comply with legal requirements, and empower all users. To get started fulfilling your EAA compliance obligations and advancing ICT accessibility, engage with our team today.