Is WCAG Conformance Enough for EAA Compliance?

Despite the looming deadline, a recent Mason Hayes Curran survey found that 49% of organisations in Ireland are not currently prepared to meet its requirements. Different surveys across other European countries reflect similar results.

The Web Content Accessibility Guidelines or “WCAG”, on the other hand, is a set of globally accepted standards developed by the W3C (World Wide Web Consortium) for web and mobile content accessibility. At the heart of WCAG is a simple but powerful framework known as POUR. This framework guides how accessible digital content should behave and forms the foundation of every WCAG success criterion. POUR stands for Perceivable, Operable, Understandable, and Robust. You can read more about this framework in our post: What is POUR and Why is it Critical to WCAG Standards?

The Connection between the EAA and WCAG: EN 301 549

Please bear with us with all these abbreviations; it’s actually not that complicated.

The key link between the WCAG and EAA is something known as EN 301 549, a European Standard for accessibility requirements for ICT products and services. A European Standard is essentially just a set of agreed rules or guidelines used across Europe to make sure products, services, or systems are safe, reliable, and work well together.

Because the EN 301 549 is a harmonised standard under EU law, it can be used to demonstrate compliance with legal accessibility requirements, like those in the European Accessibility Act (EAA). So while the EAA sets the legal obligation for digital accessibility, EN 301 549 provides the technical details of how to actually go about meeting those obligations.

EN 301 549 is not a law in and of itself; however, it can be considered a “presumption of conformity” for the EAA - i.e. it serves as the means of demonstrating compliance with the EAA.

So what is the relationship between EN 301 549 and WCAG?

Well, while EN 301 549 was originally created in 2014 with no direct link to WCAG, it was updated in 2018 to adopt the WCAG 2.1 AA standards as a key baseline of accessibility for websites, mobile apps and digital documents.

So there is your connection: WCAG forms the basis of EN 301 549, which in turn is used to demonstrate compliance with the EAA.

So WCAG 2.1 Conformance = EAA Compliance, Right?

Well, actually, not necessarily. Whilst EAA compliance will be based on EN 301 549, and EN 301 549 heavily leans on WCAG 2.1 AA standards, there are a couple of key considerations to bear in mind.

Firstly, WCAG applies primarily to web and mobile content. The scope of EN 301 549 is broader, covering other ICT products and services including both physical hardware and “hybrid” items (i.e. products that have both physical and digital components). Therefore, EN 301 549 goes beyond WCAG in its scope, with checkpoints for things like authoring tools, biometrics, two way voice communications as well as video-related checkpoints beyond those covered in WCAG.

Secondly, as per ETSI, the official European Standards Organization for ICT, EN 301 549 is in the process of being updated: “EN 301 549 will be revised with the aim to publish V4.1.1 in 2025 in support of the European Directive (EU)2019/882 on the accessibility requirements for products and services (the European Accessibility Act).”

It is widely speculated that this updated version of EN 301 549, will be based on WCAG 2.2, which in turn suggests that the European Accessibility Act will then be predicated on WCAG 2.2 on levels A and AA.

WCAG, EN 301 549 and EAA - Compared

	WCAG	EN 301 549	EAA
What is it?	Voluntary technical guidelines	European standard (harmonised standard)	EU directive (legal requirement for Member States)
Who is it published by?	W3C (World Wide Web Consortium)	ETSI (with CEN & CENELEC)	European Union
What is its legal status?	Not legally binding by itself	Can carry legal weight when referenced in EU law	Legally binding when transposed into national law
What is its scope?	Digital content only: websites, apps, documents	ICT products and services: websites, apps, software, hardware, ATMs, e-readers, etc.	Broad: requires accessibility of certain products and services in the EU
What is its focus?	Accessibility of web/mobile content	Accessibility of digital and hybrid ICT	Equal access to key products & services for people with disabilities
What is it used for?	Designing and auditing accessible websites/apps	Proving accessibility compliance for public procurement & EAA	Regulatory compliance across EU for covered services/products
How is it enforced?	Technically it isn't. Only enforced if adopted by law	Enforced when linked to EU law (e.g. EAA or public contracts)	Enforced by national authorities with penalties for non-compliance

Conclusion

If your organisation falls within the scope of the European Accessibility Act, conforming with WCAG 2.1 AA standards is a great place to start on your journey to achieving compliance. However there are a few things to bear in mind:

1. EN 301 549 is set to be revised in line with WCAG 2.2 sometime in 2025 - so that is likely to be the new standard for EAA compliance at some point in the near future. With that in mind, you should aim for conformance with WCAG 2.2 AA to futureproof your websites and digital products.

2. Whilst WCAG conformance is likely to ensure that your web content is in compliance with the EAA, be mindful that WCAG conformance will not necessarily suffice if you also have consumer-facing hybrid items (e.g. ticket machines, ATMs, POS terminals, kiosks, etc.) or if your products integrate with biometrics, authoring tools, two way voice communications, etc.

Nexus Inclusion’s Commitment to Digital Inclusion

At Nexus Inclusion, we believe that accessibility alone is not enough. Our mission is to prioritise inclusion as a core element of every digital experience, ensuring that people of all abilities are not just accommodated, but fully engaged in the digital world. By combining human insight with advanced technology, we help organisations of all sizes meet the requirements of the European Accessibility Act and create truly inclusive digital products.

Founded by Kyran O'Mahoney, Nexus Inclusion is backed by a dedicated team of accessibility experts who are passionate about building a more inclusive online environment. With extensive experience and a clear purpose, the team is here to support businesses at every step of their journey.

Our AI-driven platform plays a vital role in scaling accessibility efforts, offering efficient, reliable tools for assessment, remediation, and ongoing compliance. Sign up here for early access.