If you’re responsible for compliance with the European Accessibility Act (Directive (EU) 2019/882), you might ask: can I just follow WCAG?
The answer is: generally, yes, for purely digital assets, but not everything. Also, remember that there are administrative obligations beyond the purely technical accessibility requirements.
Here’s what you need to know when it comes to WCAG and the EAA.
When WCAG Is Sufficient
Digital Services
Generally, for most digital products and services, the technical accessibility requirements under the EAA can be satisfied by conforming to WCAG 2.1 AA.
Covered Services Where WCAG Can Work:
- Websites and web applications
- Mobile apps
- E-commerce platforms
- E-book platforms and e-readers
- Online banking and digital financial services
- Digital interfaces for transportation (e.g., ticket booking, travel info)
- Audiovisual content interfaces, including electronic TV guides
Why WCAG Works:
Annex I of the EAA sets out functional accessibility requirements that align with WCAG’s core principles:
- Perceivable: Information must be available to all senses (e.g., alt text, captions).
- Operable: Interfaces must be usable via different input methods (e.g., keyboard).
- Understandable: Content must be clear and predictable.
- Robust: Content must work with a range of user agents and assistive technologies.
If your websites and apps meet WCAG 2.1 AA, you’re likely compliant with the EAA’s requirements for digital content.
Also, note that EN 301 549 is the European standard that contains accessibility requirements for ICT products and services. EN 301 549 incorporates WCAG 2.1 AA by reference and although conformance with EN 301 549 doesn’t create a presumption of conformity (yet), this is very compelling when it comes to EAA compliance.
When WCAG Is Not Enough
There are key situations where WCAG alone is not sufficient.
Physical Products and Hybrid Interfaces
For the following, WCAG does not cover all requirements in Annex I:
- ATMs and ticket machines
- Self-service terminals
- Smartphones and operating systems
- Payment terminals
- Consumer hardware (e.g., routers, modems)
- Emergency communication systems
These products must meet additional functional requirements beyond digital presentation, including:
- Tactile feedback
- Speech output
- Physical button accessibility
- Screen visibility in various lighting conditions
- Volume and contrast adjustments
Built Environment (Annex III)
While optional for Member States, built environment accessibility (e.g., physical location where services are provided) may also apply. WCAG does not address physical accessibility—Annex III does.
Recommendations
If You’re a Digital Service Provider:
- Follow WCAG 2.1 Level AA at a minimum.
- Consider WCAG 2.2 AA to improve usability and future-proof your implementation.
If You’re a Manufacturer or Offer Hybrid Services:
- Use Annex I as your baseline and treat WCAG as a partial solution.
- Assess your product against hardware interaction standards—such as EN 301 549 if applicable.
Chart
| Situation | Is WCAG Enough? |
|---|---|
| Website or web app | Yes |
| Mobile application | Yes |
| E-book reader interface | Yes |
| E-commerce platform | Yes |
| ATM or ticketing machine | No |
| Smartphone hardware | No |
| Emergency communication hardware/software | No |
| Physical service environment | No (use Annex III) |
Summary
You can rely on WCAG for most digital accessibility requirements under the EAA—but not for physical products, hardware, or hybrid systems. For full compliance, especially with Annex I, you’ll need to go beyond WCAG when required.
Services
Accessible.org can help you take care of EAA compliance. Accessible.org is a digital accessibility company led by me, Kris Rivenburgh, an attorney who literally wrote the book on Digital Accessibility and Compliance (available on Amazon).