EN 301 549: the clauses that apply to a website

EN 301 549 is the European standard for the accessibility of ICT: websites, software, documents and hardware. For a website under the European Accessibility Act, the current version, V4.1.1, sends you to Table A.1 in Annex A: 57 rows, each under the condition “Where ICT is, or includes, a web page”.

They are the 55 WCAG 2.2 success criteria at Level A and AA, plus two clauses of the standard’s own: 9.6, WCAG’s conformance requirements, and 9.7, user preferences. Table A.5 then adds rows that apply only if your site has the feature they describe, such as video or voice calls.

This post lists every row of Table A.1 and groups the 106 rows of Table A.5, counted from the ETSI documents.

Our guide to the European Accessibility Act for websites covers the law these tables serve.

Which version, which annex

Annex A means different things in the two versions you will meet.

• In V4.1.1 (September 2026), Annex A is the route for the European Accessibility Act. Its clause A.2 holds five tables, A.1 to A.5. The public-sector route moved to Annex ZA.
• In V3.2.1 (2021), Annex A was the route for the Web Accessibility Directive, the one that is cited today, and its Table A.1 is that Directive’s table for websites.

Both versions say the tables give a presumption of conformity only “once the present document is cited in the Official Journal of the European Union under that Directive”. So V4.1.1’s Annex A tells you what conformance with the standard will mean once it is cited; until then it gives no presumption under the Act, and the Act’s requirements reach you through national law. Whether the Act covers you at all is the earlier question; we go through it in a step-by-step check of whether the Act applies to you.

How Annex A is meant to be read

Clause A.2.0 sets the order: “Each of the clauses in clause A.2 shall be considered, in sequential order, to see whether the condition that is stated in the clause title, and in the introduction to the table within that clause, is applicable to the ICT being evaluated.” Where a clause applies, you assess the rows in its table whose own condition applies.

A typical website meets the first, may meet the second and third, and meets some rows of the fifth.

The 57 rows for a web page

Every row of Table A.1 carries the same condition: “Where ICT is, or includes, a web page”. Each clause 9 requirement says the web page “shall satisfy” the matching WCAG 2.2 success criterion, so the table below is WCAG 2.2 Level A and AA with two additions at the end. Each criterion links to its entry in our WCAG 2.2 checklist, with code that passes and fails.

Two rows are not WCAG success criteria:

• 9.6 WCAG conformance requirements brings in WCAG’s five conformance requirements at Level AA: the conformance level, full pages, complete processes, only accessibility-supported ways of using technologies, and non-interference. The standard’s note says they apply “when checking conformance of all requirements in clauses 9.1 to 9.4”.
• 9.7 User preferences for web pages says a page “shall not block the user agent’s mode(s) of operation that present the web page according to user preference settings, or explicitly override user preference settings for documented platform accessibility features in these modes of operation, unless this is essential to the information or function of the web page”. Its note names CSS forced-color-adjust as an example of an override to use only where essential. We look at how 9.7 works in practice.

Rows a website triggers with its features

Table A.5 applies to all ICT, and each of its 106 rows has its own condition. Read them against what your site does. Our grouping below is a reading of those conditions, not ETSI’s classification; check each row’s condition in the standard.

Clause 12’s rows matter for most services: information about a service in digital form has to meet clause 9, 10 or 11 for its format (12.2), and where there is documentation or an official web page about using the service, it has to include or link to information on its accessibility features, how to use them and how to get support (12.3). See what Annex V asks a service to publish.

Downloadable documents and apps

• Table A.2, non-web documents, holds clause 10’s 54 rows. It applies to documents that are not web pages, such as a PDF a visitor downloads. A document embedded in a page and rendered with it is covered by clause 9 as part of that page.
• Table A.3, non-web software, holds clause 11’s 68 rows. It applies to software that is not a web page, such as a mobile app you offer next to the site; the standard notes that an app’s web views are not web pages.

Public-sector websites: V3.2.1 and Annex ZA

For a public-sector site under the Web Accessibility Directive, the cited standard is V3.2.1, and its Table A.1 has 137 rows. Six are unconditional (11.7, 12.1.1, 12.1.2, 12.2.2, 12.2.3 and 12.2.4); the other 131 carry a condition. By clause, they are 3 rows from clause 5, 19 from clause 6, 9 from clause 7, 50 from clause 9, 45 from clause 10, 6 from clause 11 and 5 from clause 12. The 50 clause 9 rows are 49 WCAG 2.1 criteria at Level A and AA, including 4.1.1 Parsing and without 1.2.4 live captions, plus 9.6.

In V4.1.1 the Directive’s tables moved to Annex ZA. Table ZA.1 has 127 rows, with no clause 10 or 11 rows, and its 56 clause 9 rows are the web-page rows of Table A.1 without 9.1.2.4 Subtitles (live): the Directive does not apply to live time-based media, its note says. ZA.1 includes 9.7. Its own scope still lists documents downloadable from web pages, and V3.2.1’s table had 45 clause 10 rows, so keep testing a public body’s downloadable documents against clause 10. Once V4.1.1 is cited under that Directive, conformance with these rows gives the presumption of conformity; what a public body must do is set by its national law.

What changed from V3.2.1

For clause 9, the web-page clauses, 49 rows are in both tables. The rest:

In clause 9 itself, 9.1.2.4 was renamed too, from “Captions (live)” to “Subtitles (live)”. The condition changed as well, from “Where ICT is a web page” to “Where ICT is, or includes, a web page”.

What this means for testing

• Every website: test the 57 rows of Table A.1, which is WCAG 2.2 Level A and AA, the five conformance requirements, and 9.7. While V3.2.1 is the cited standard for public-sector sites, keep 4.1.1 Parsing on the list too.
• By feature: add the Table A.5 rows whose conditions your site meets: video, real-time communication, authoring, product and service information.
• Documents and apps: test downloadable documents against clause 10 and apps against clause 11.
• Evidence: record which rows you judged not applicable, and why.
• People: many of these rows can only be judged by people, including testing with assistive technologies. Automated checks cover part of the list, and no tool’s result is a conformance statement.