EN 301 549 Compliance

Understanding EN 301 549: The European Accessibility Standard

EN 301 549 is the harmonized European standard that defines accessibility requirements for ICT products and services. Published by ETSI (European Telecommunications Standards Institute), it serves as the technical specification that underpins the European Accessibility Act and the Web Accessibility Directive.

Unlike WCAG, which focuses specifically on web content, EN 301 549 provides a comprehensive framework covering web content (Section 9), non-web documents (Section 10), software applications (Section 11), and documentation and support (Section 12). For organizations dealing with PDF accessibility, Section 10 is particularly critical—it adapts WCAG principles specifically for documents like PDFs, Word files, and spreadsheets.

The current harmonized version is EN 301 549 v3.2.1 (published 2021), which incorporates WCAG 2.1 Level AA. ETSI is expected to publish an updated version incorporating WCAG 2.2 to align with the European Accessibility Act's evolving requirements—organizations should monitor official ETSI publications for updates.

Section 10: Non-Web Document Requirements for PDFs

Section 10 of EN 301 549 adapts WCAG 2.1 success criteria specifically for non-web documents. While the requirements mirror WCAG, they're contextualized for document formats rather than web pages. Understanding these adaptations is essential for PDF compliance.

10.1.1.1 Non-text Content All images, charts, and graphics in PDFs must have text alternatives. This maps directly to WCAG 1.1.1 but applies to document context—meaning infographics in annual reports and charts in financial documents all require alt text.

10.1.3.1 Info and Relationships Document structure must be conveyed through proper PDF tags, not just visual formatting. Headings must use heading tags (H1-H6), lists must use list tags, and tables must have proper header cell markup.

10.1.3.2 Meaningful Sequence The reading order defined in the PDF tag structure must match the logical reading order of the content. This is critical for multi-column layouts and complex page designs.

10.2.1.1 Keyboard All interactive elements, particularly form fields, must be operable via keyboard alone. Users must be able to tab through fields and activate buttons without a mouse.

10.2.4.2 Document Titled PDFs must have a meaningful title in document properties—not just the filename. "Q3-2024-Financial-Report.pdf" is insufficient; the title property should read "Q3 2024 Financial Report."

10.4.1.2 Name, Role, Value Form fields must have programmatically determinable names (labels), roles (text field, checkbox, etc.), and current values. Screen readers rely on this information to convey form structure to users.

EN 301 549 vs WCAG: Key Differences for Document Compliance

While EN 301 549 Section 10 is based on WCAG, there are important distinctions that affect how you approach document accessibility compliance.

Scope of Application WCAG was designed for web content and must be interpreted for document contexts. EN 301 549 provides that interpretation explicitly—Section 10 tells you exactly how each criterion applies to documents. This removes ambiguity about whether a WCAG criterion is relevant to PDFs.

Legal Standing in Europe WCAG is a W3C recommendation with wide international recognition. EN 301 549 is the legally harmonized standard in Europe—it's what the European Accessibility Act and Web Accessibility Directive reference. When European regulators assess compliance, they check against EN 301 549, which incorporates WCAG by reference. Your compliance documentation must reference EN 301 549 specifically—WCAG conformance alone is insufficient for EU regulatory purposes.

Beyond Section 10: The Full Picture EN 301 549 includes requirements beyond WCAG that apply to document workflows. Section 12.1 requires that product documentation describing accessibility features be provided in accessible formats—meaning your PDF user guides must themselves be accessible. Section 12.2 requires that support services communicate accessibility information to users. Many organizations focus solely on Section 10 and overlook these broader obligations.

Practical Compliance Approach For PDF accessibility, achieving WCAG 2.1 AA compliance will satisfy most EN 301 549 Section 10 requirements. However, European organizations should audit specifically against EN 301 549 to ensure complete coverage. At EqualXS, we audit against the full standard—not just the document-specific sections—to ensure comprehensive compliance.

Implementing EN 301 549 Compliance for Your Documents

Achieving EN 301 549 compliance for documents requires understanding both the technical requirements and the legal context. Here's a practical implementation approach based on our work with European organizations.

Step 1: Determine Your Obligations Public sector organizations have been required to comply since the Web Accessibility Directive took effect in 2018. Private sector organizations must ensure products and services placed on the market after June 28, 2025 meet European Accessibility Act requirements—this covers e-commerce, banking services, transport services, e-books, and more. Documents integral to these services fall within scope.

Step 2: Inventory Your Documents Catalog all documents that fall under compliance scope. This includes PDFs published on websites, documents provided to customers, and internal documents used for service delivery. Prioritize customer-facing documents and those with legal significance—contracts, terms of service, and regulatory filings carry the highest risk.

Step 3: Audit Against EN 301 549 Test documents against EN 301 549 Section 10 requirements. Use automated tools like PAC 2024 (PDF Accessibility Checker) for initial screening—it validates against PDF/UA and the Matterhorn Protocol, which align with EN 301 549. Then conduct manual review with screen readers (NVDA, JAWS, VoiceOver) to catch issues automation misses. Document your findings in a compliance report mapping to specific Section 10 requirements.

Step 4: Remediate Non-Conformances Fix identified issues to meet all applicable requirements. This typically involves adding proper PDF tags, correcting reading order, adding alternative text, fixing form field accessibility, and setting document metadata. For template-generated documents, fix the source templates to prevent recurring issues.

Step 5: Obtain Certification EN 301 549 compliance certification provides evidence for procurement requirements and regulatory audits. EqualXS provides EN 301 549 compliance certificates with detailed testing documentation that satisfies EU public procurement requirements.

Step 6: Establish Ongoing Processes Accessibility is not a one-time project. Train document creators on accessibility requirements, implement quality gates before publication, and schedule regular compliance audits as regulations and standards evolve.