The European Accessibility Act and EN 301 549 — what I could verify, and what I couldn’t

Every claim below was checked against a primary source on 23 August 2026, and the one I could not check is marked as such rather than smoothed over.

If you run a website in the EU and you have started reading about the European Accessibility Act, you have met a confident sentence naming the standard you are supposed to meet. You may also have noticed that the confident sentences do not agree with each other. Some name WCAG 2.1 Level AA. Some name 2.2.

I went looking for the primary source instead. Here is what I found — including the part where I came up empty.

What is verifiable

EN 301 549 V3.2.1 is a harmonised European standard. It is cited by Commission Implementing Decision (EU) 2021/1339, which EUR-Lex still lists as in force. For web content the standard carries WCAG 2.1 Level AA verbatim, without modification — that last point is stated plainly by the W3C’s Web Accessibility Initiative.

So far this matches what most articles will tell you.

The part I have not seen mentioned

Read what that Decision is actually about.

It is adopted under Regulation (EU) No 1025/2012 on European standardisation, and it concerns Directive (EU) 2016/2102 — the Web Accessibility Directive. That directive covers public sector bodies: government departments, municipalities, public institutions.

It does not mention the European Accessibility Act anywhere in its text.

The European Accessibility Act is a different law. Directive (EU) 2019/882. It covers private business, and it has been applying since 28 June 2025.

Two directives, two scopes. The Decision that harmonises EN 301 549 belongs to the public sector one.

What I could not verify

The EAA has the same mechanism available to it: conformity with harmonised standards whose references have been published in the Official Journal creates a presumption of conformity with the Act’s accessibility requirements. That is in the directive’s own text.

What I could not find is that publication. I looked for an Implementing Decision citing a harmonised standard under Directive (EU) 2019/882 and did not find one. The European Commission’s harmonised-standards page for it returned a 404. ETSI returns 403 to an automated request. Every source I could actually read asserting that EN 301 549 is harmonised for the EAA was a blog post rather than a legal instrument.

I want to be careful here, because this is exactly the sort of gap that is tempting to fill. I am not claiming that no such citation exists. I am saying I looked for it, did not find it, and will not state it as fact — because stating it would make this article sound more authoritative than it has earned.

If you know where it sits, I would genuinely like the link.

Why this matters if you own a site

Not because it changes what you should build. Accessible markup, real alt text, keyboard navigation and sufficient contrast are worth doing whichever directive number applies to you.

It matters because of the paperwork. An accessibility statement names a standard. If you are a private business in the EU and your statement cites EN 301 549, it is worth knowing whether you are citing it because it is legally harmonised for your situation, or because it is what everyone in the industry points at. Those are different positions, and only one of them survives a lawyer asking why.

Two things worth ten minutes today:

• Check which standard your accessibility statement actually names.
• Check whether it carries a date. An undated statement reads as abandoned to anyone reviewing it.

Sources

• Commission Implementing Decision (EU) 2021/1339 — cites EN 301 549 V3.2.1; adopted under Regulation (EU) No 1025/2012; concerns Directive (EU) 2016/2102.
• Directive (EU) 2019/882 — the European Accessibility Act
• W3C Web Accessibility Initiative — European Union policies — EN 301 549 includes WCAG 2.1 Level AA verbatim for web content.

Disclosure

I build accessibility tooling for WordPress, so I have a commercial interest in you thinking about this subject at all. That is also why I would rather be right than confident: in this field the vendors who overstate are the reason the whole category is distrusted.

Yury — yugodev.eu, Lithuania, EU