The European Accessibility Act does not name a WCAG version directly. It points to harmonized standard EN 301 549, which incorporates WCAG 2.1 Level AA as the technical baseline for websites, mobile apps, and other digital products covered by the law. Companies in scope need to meet WCAG 2.1 AA at a minimum to be considered in conformance under the EAA.
This is the short version. The longer version is worth reading because the relationship between the EAA, EN 301 549, and WCAG shapes how audits, documentation, and remediation projects should be scoped.
| Reference Point | Detail |
|---|---|
| Required WCAG version | WCAG 2.1 Level AA |
| Harmonized standard | EN 301 549 (latest version) |
| Effective date | June 28, 2025 |
| Scope | Websites, mobile apps, ecommerce, banking, ebooks, ticketing, and other covered products |
| Documentation | Accessibility statement and technical records of conformance |
Why the EAA Points to EN 301 549 Instead of WCAG Directly
The EAA is a directive. It sets the legal requirement that products and services be accessible, but it leaves the technical details to harmonized European standards.
EN 301 549 is the harmonized standard the EU uses to spell out what accessible actually means for information and communication technology. For web and mobile content, EN 301 549 adopts WCAG 2.1 Level AA success criteria directly. So when a company asks what WCAG version is required under the EAA, the answer runs through EN 301 549.
Meeting WCAG 2.1 AA is the web and mobile portion of EN 301 549 conformance. EN 301 549 covers more ground than WCAG alone, including hardware, documentation, and support services, but WCAG 2.1 AA is the core for digital content.
Is WCAG 2.2 AA Required Under the EAA?
Not yet. The current referenced version in EN 301 549 is WCAG 2.1 AA. WCAG 2.2 was published in October 2023, and EN 301 549 is expected to update to reference WCAG 2.2 in a future revision, but that update has not taken legal effect for EAA purposes.
Companies with time and budget often go ahead and target WCAG 2.2 AA voluntarily. The newer criteria cover real usability issues, and auditing to 2.2 AA now means less rework when the standard updates. For strict EAA conformance today, 2.1 AA is what the law points to.
What the EAA Actually Requires in Practice
A company in scope of the EAA needs to evaluate digital products against WCAG 2.1 AA through a manual accessibility audit, address the issues the audit identifies through remediation, publish an accessibility statement describing conformance status, and keep technical documentation that supports the conformance claim.
Automated scans are not enough. Scans only flag approximately 25% of issues, and EAA enforcement bodies can request documentation that goes well beyond what a checker can produce. A manual audit from a qualified auditor is the path to a defensible conformance claim.
Who Is in Scope?
The EAA covers businesses offering certain products and services in the EU, including ecommerce, consumer banking, ebooks, passenger transport, and telecommunications. Microenterprises providing services are generally exempt, but the definition is narrow. Most mid-sized and larger companies selling to EU consumers are in scope.
Non-EU companies are not off the hook. If you sell into the EU market, the EAA applies to your digital products and services the same way it applies to EU-based companies.
How Does EAA Conformance Connect to ADA and Section 508?
All three regulatory frames point to WCAG as the technical reference. ADA Title II names WCAG 2.1 AA for state and local government web content. Section 508 references EN 301 549 through revised 508 standards, and EN 301 549 references WCAG 2.1 AA.
A company that meets WCAG 2.1 AA on its websites and mobile apps is doing most of the work for ADA, Section 508, and EAA conformance at once. The documentation artifacts differ (ACR for Section 508 procurement, accessibility statement for the EAA), but the underlying technical standard is consistent.
Frequently Asked Questions
Does meeting WCAG 2.1 AA mean I am fully EAA compliant?
For web and mobile content, yes, that is the technical core. Full EAA compliance also requires the accessibility statement, technical documentation, and any product-specific requirements that apply to your category under EN 301 549.
Can I claim conformance based on an automated scan alone?
No. Scans detect around 25% of issues. Conformance with WCAG 2.1 AA requires manual evaluation by an auditor who can assess criteria that automated checkers cannot evaluate, including keyboard operability, focus order, and the accuracy of alt text.
Should I audit to WCAG 2.1 AA or 2.2 AA for the EAA?
For legal conformance today, 2.1 AA is the required version. If you want future-proofing and better user outcomes, auditing to 2.2 AA covers 2.1 AA and the newer criteria at the same time.
Do mobile apps fall under the EAA?
Yes. EN 301 549 covers mobile apps, and WCAG 2.1 AA success criteria apply to mobile interfaces through the standard. An EAA project scope often includes web and mobile together.
What happens if I do not meet EAA requirements?
Enforcement is at the member state level. Penalties vary by country and can include fines, corrective orders, and removal of products from the market. Complaints from users can trigger enforcement action.
The EAA is active law across the EU. If you sell into the market, WCAG 2.1 AA is the version to audit against, and EN 301 549 is the standard to reference in your documentation.
Contact Kris for help scoping an EAA conformance project: krisrivenburgh.com/contact.