Technique · EN 301 549 · ETSI, CEN and CENELEC
EN 301 549 — the standard nobody reads and everybody has to meet
The Polish Accessibility Act never mentions WCAG. It speaks of “perceivability, operability, understandability and compatibility” (art. 12(2)(3)) and of a presumption of conformity for whatever meets a harmonised standard (art. 20). That standard is EN 301 549 — “Accessibility requirements for ICT products and services”. Its clause 9 restates the WCAG 2.1 level A and AA success criteria as technical requirements. That is the whole mechanism: law → standard → WCAG.
Who publishes it, and where it came from
EN 301 549 is a joint standard of the three European standardisation organisations — ETSI, CEN and CENELEC — originally written on a European Commission request (mandate M/376) as a set of accessibility requirements for public procurement of ICT. The first version dates from 2014. Version V3.2.1 (2021‑03) is the one the Commission cited in the Official Journal of the European Union under Directive 2016/2102 on the accessibility of public sector websites. That citation is not a formality: it is what turns a voluntary standard into a harmonised one, and a harmonised standard is what a presumption of conformity flows from.
Under the European Accessibility Act the Commission asked the same organisations to update the standard (mandate M/587). ETSI has published a newer version, but to date none has been cited in the Official Journal under the EAA. The practical consequence for a company is single and worth remembering: the formal presumption of conformity under art. 20(1) of the Polish act is not operating yet, and the only measure an enforcement body will reach for is EN 301 549 anyway — that is, WCAG 2.1 AA.
What is inside — clause by clause
| Clause | What it covers | Who should care |
|---|---|---|
| 4 | Functional performance statements — eleven user situations (without vision, without hearing, with limited manipulation…) | everyone; this is the “why” behind the rest |
| 5 | Generic requirements: activation of accessibility features, biometrics, preservation of information, authorised access | hardware and platform makers |
| 6 | ICT with two-way voice communication (RTT, video calls, audio quality) | telecoms, messaging apps |
| 7 | ICT with video capabilities: captions, audio description, and carrying both through the whole chain | media, VOD, e‑learning |
| 8 | Hardware: ATMs, ticket machines, terminals, keyboards | banking, transport, retail |
| 9 — “Web” | WCAG 2.1 A and AA, criterion by criterion, as requirements 9.1.1.1 – 9.4.1.3, plus 9.6 (WCAG conformance requirements) | every website and every shop |
| 10 | Non-web documents: PDF, DOCX, spreadsheets, e‑books — the same criteria applied to a file | anyone who publishes PDFs and terms |
| 11 | Software, including mobile apps: the same criteria plus user preferences and authoring tools | iOS/Android apps, CMS platforms |
| 12 | Documentation and support services: manuals and help must themselves be accessible and describe the accessibility features | customer service, legal |
| 13 | Relay services and access to emergency numbers | telecoms, public sector |
Then the annexes: A (relationship with EU law), B (the correspondence table with WCAG), C (the checklist used for conformity assessment, filled in “satisfied / not satisfied / not applicable”) and D–E (guidance). When somebody asks you for a “declaration of conformity with EN 301 549”, they almost always mean a completed Annex C.
Clause 4: eleven situations, not eleven diagnoses
Clause 4 is the only part of the standard written in human language rather than in code. It describes use without vision, with limited vision, without perception of colour, without hearing, with limited hearing, without vocal capability, with limited manipulation or strength, with limited reach, with limited cognition, with minimised photosensitive seizure triggers, and with privacy. That last one is the most frequently forgotten: if the only route to the goal is having your balance read out loud or asking the cashier for help, the feature is accessible and the service is not.
What it means for a site owner
- Site and shop: clause 9 = WCAG 2.1 AA. You do not have to buy the standard to know what to do — the WCAG criteria are public and identical in substance.
- Mobile app: clause 11, not 9. The same criteria, but tested in the operating system rather than the browser — with TalkBack and VoiceOver.
- PDFs and terms: clause 10. Terms and conditions in an untagged PDF are non-conformant even when the site around them is exemplary. How to fix that.
- Support: clause 12. The complaints channel required by art. 37 is a service too — a contact form a screen reader cannot use closes the route of appeal.
- You do not need a certificate. There is no certification body for services in this system; there is your own conformity assessment (art. 32(1)) and documentation you must be able to produce.
How to cite it so that it means something
“Compliant with EN 301 549”, with no version, no clause and no date of testing, is decoration rather than a statement. A useful sentence looks like this:
“The conformity assessment of the service was carried out on 12 March 2026 against EN 301 549 V3.2.1, clause 9 (WCAG 2.1 level AA). Conformity was established with the exception of criteria 1.2.5 and 2.5.8 on archived pages; remediation planned by 30 June 2026.”
The kind of paragraph an enforcement body takes seriously — because it has scope, a date, a version of the standard and a list of exceptionsExceptions are not a confession. An exception recorded with a remediation date is evidence that the assessment actually happened; no exceptions at all in a first assessment is a sign that it did not.
Where to read it
The standard is available free of charge as a PDF from ETSI (document EN 301 549 in the standards register). It runs to over 150 pages and is written for test laboratories, not for shop owners. A reading order that saves a week: clause 4 (why), the table in Annex B (what maps to what in WCAG), then clause 9 or 10 or 11 — whichever applies to your product — and Annex C when it is time to document.