WCAG is part of EN 301 549 but EN 301 549 goes way beyond WCAG

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I don’t like the fact that EN 301 549 is provided in PDF format. It’s way simpler to process HTML. And when I did some parsing I figured out I could also check how exactly does EN 301 549 goes beyond WCAG for web and mobile applications. Quite a lot is the short answer.

We often read that Web Accessibility Directive refers to standard EN 301 549 that includes Web Content Accessibility Guidelines 2.1 on levels A and AA. But if we don’t actually check the whole EN 301 549 then we may think that it only includes WCAG and a bit more. The reality is that EC 301 549 includes a lot more of success criteria than WCAG as it needs to cover accessibility beyond web. It can also be applied to native mobile applications, documents and also other digital solutions.

In this post I present where EN 301 549 actually goes beyond WCAG and which parts of it are applicable for web and which for mobile. I think this can be of value for people not familiar with EN 301 549 that do know at least basics of WCAG. WAD in Norway is a bit simpler than in the rest of the EU, so I guess there are potentially a lot of people not aware of the whole EN 301 549 and I hope this post will shed some light on the whole standard.

43 out of 76 EN 301 549 success criteria are applicable to web and 32 to mobile applications alone

After processing all 76 EN 301 549 (version 3.2.1) success criteria I got to these numbers.

43 out of 76 success criteria that go beyond WCAG in EN 301 549 are applicable to websites and some of them also for mobile applications and other so called ICT technologies.

It’s important to understand what does ICT stand for:

Information and Communication Technology (ICT) : technology, equipment, or interconnected system or subsystem
of equipment for which the principal function is the creation, conversion, duplication, automatic acquisition, storage,
analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission,
reception, or broadcast of data or information

Definition of ICT from EN 301 549 (PDF, opens in new window).

The standard also includes examples of ICT, so to be totally clear about it:

Note: Examples of ICT are web pages, electronic content, telecommunications products, computers and
ancillary equipment, software including mobile applications, information kiosks and transaction
machines, videos, IT services, and multifunction office machines which copy, scan, and fax documents.

A brief note from the standard that provides examples of ICT.

So, as mentioned in the start EN 301 549 goes way beyond WCAG also in terms of technologies that are applicable. Besides webpages and mobile applications it can also be applied on hardware and that covers a lot more.

But let’s focus back on the web and mobile.

32 out of 76 success criteria that go beyond WCAG in EN 301 549 are applicable to mobile applications alone.

So, we have 43 success criteria that go beyond WCAG for web and 32 that go beyond WCAG for native mobile applications. That gives us almost double success criteria in theory.

Basically we can establish that EN 301 549 includes almost twice as much success criteria for web and mobile. A bit less for mobile, but still quite a lot. Of course not all success criteria are applicable for all webpages and mobile applications and in practical terms we don’t need to check all EN 301 549 on all webpages and mobile applications. But we still need to check if they apply before we can be certain.

To conclude I also provide the data that I got the numbers from. It’s based on latest version of EN 301 549 at the time of writing (version 3.2.1), to be clear about it.

43 out of 76 EN 301 549 success criteria are applicable to web and 32 to mobile applications alone
# Web Only mobile Group title Criteria title Condition
1 Y N 5.2 Activation of accessibility features 5.2: Activation of accessibility features Condition: Where web content or ICT has documented accessibility features
2 Y N 5.3 Biometrics 5.3: Biometrics Condition: Where web content or ICT uses biological characteristics
3 Y N 5.4 Preservation of accessibility information during conversion 5.4: Preservation of accessibility information during conversion Condition: Where web content or ICT converts information or communication
4 N Y 5.5 Means of operation 5.5.1: Means of operation Condition: Only for mobile applications: Where ICT has operable parts
5 N Y 5.5 Means of operation 5.5.2: Operable parts discernibility Condition: Only for mobile applications: Where ICT has operable parts
6 N Y 5.6 Locking or toggle controls 5.6.1: Tactile or auditory status Condition: Only for mobile applications: Where ICT has a locking or toggle control
7 N Y 5.6 Locking or toggle controls 5.6.2: Visual status Condition: Only for mobile applications: Where ICT has a locking or toggle control
8 N Y 5.7 Key repeat 5.7: Key repeat Condition: Only for mobile applications: Where ICT has a key repeat function that cannot be turned off
9 N Y 5.8 Double-strike key acceptance 5.8: Double-strike key acceptance Condition: Only for mobile applications: Where ICT has a keyboard or keypad
10 N Y 5.9 Simultaneous user actions 5.9: Simultaneous user actions Condition: Only for mobile applications: Where ICT uses simultaneous user actions for its operation
11 Y N 6.1 Audio bandwidth for speech 6.1: Audio bandwidth for speech Condition: Where web pages or ICT provide two-way voice communication
12 Y N 6.2 Real-Time Text (RTT) functionality 6.2.1.1: RTT communication Condition: Where web pages or ICT provide a means for two-way voice communication
13 Y N 6.2 Real-Time Text (RTT) functionality 6.2.1.2: Concurrent voice and text Condition: Where web pages or ICT provide a means for two-way voice communication and for users to communicate by RTT
14 Y N 6.2 Real-Time Text (RTT) functionality 6.2.2.1: Visually distinguishable display Condition: Where web pages or ICT have RTT send and receive capabilities
15 Y N 6.2 Real-Time Text (RTT) functionality 6.2.2.2: Programmatically determinable send and receive direction Condition: Where web pages or ICT have RTT send and receive capabilities
16 Y N 6.2 Real-Time Text (RTT) functionality 6.2.2.3: Speaker identification Condition: Where web pages or ICT have RTT capabilities, and provide speaker identification for voice
17 Y N 6.2 Real-Time Text (RTT) functionality 6.2.2.4: Visual indicator of Audio with RTT Condition: Where web pages or ICT provide two-way voice communication, and have RTT capabilities
18 Y N 6.2 Real-Time Text (RTT) functionality 6.2.3.a: Interoperability item a) Condition: Where web pages or ICT with RTT functionality interoperate with other ICT with RTT functionality (as required by clause 6.2.1.1)
19 Y N 6.2 Real-Time Text (RTT) functionality 6.2.3.b: Interoperability item b) Condition: Where web pages or ICT with RTT functionality interoperate with other ICT with RTT functionality (as required by clause 6.2.1.1)
20 Y N 6.2 Real-Time Text (RTT) functionality 6.2.3.c: Interoperability item c) Condition: Where web pages or ICT with RTT functionality interoperate with other ICT with RTT functionality (as required by clause 6.2.1.1)
21 Y N 6.2 Real-Time Text (RTT) functionality 6.2.3.d: Interoperability item d) Condition: Where web pages or ICT with RTT functionality interoperate with other ICT with RTT functionality (as required by clause 6.2.1.1)
22 Y N 6.2 Real-Time Text (RTT) functionality 6.2.4: RTT responsiveness Condition: Where web pages or ICT utilise RTT input
23 Y N 6.3 Caller ID 6.3: Caller ID Condition: Where web pages or ICT provide caller identification or similar telecommunications functions
24 Y N 6.4 Alternatives to voice-based services 6.4: Alternatives to voice-based services Condition: Where web pages or ICT provide real-time voice-based communication and also provide voice mail, auto-attendant, or interactive voice response facilities
25 Y N 6.5 Video Communication 6.5.2: Resolution item a) Condition: Where web pages or ICT that provide two-way voice communication includes real-time video functionality
26 Y N 6.5 Video Communication 6.5.3: Frame rate item a) Condition: Where web pages or ICT that provide two-way voice communication includes real-time video functionality
27 Y N 6.5 Video Communication 6.5.4: Synchronization between audio and video Condition: Where web pages or ICT that provide two-way voice communication includes real-time video functionality
28 Y N 6.5 Video Communication 6.5.5: Visual indicator of audio with video Condition: Where web pages or ICT that provide two-way voice communication includes real-time video functionality
29 Y N 6.5 Video Communication 6.5.6: Speaker identification with video (sign language) communication Condition: Where web pages or ICT provide speaker identification for voice users
30 Y N 7.1 Caption processing technology 7.1.1: Captioning playback Condition: Where web content or ICT displays video with synchronized audio
31 Y N 7.1 Caption processing technology 7.1.2: Captioning synchronization Condition: Where web content or ICT displays captions
32 Y N 7.1 Caption processing technology 7.1.3: Preservation of captioning Condition: Where web pages or ICT transmit, convert or record video with synchronized audio
33 Y N 7.1 Caption processing technology 7.1.4: Captions characteristics Condition: Where web content or ICT displays captions
34 Y N 7.1 Caption processing technology 7.1.5: Spoken subtitles Condition: Where web content or ICT displays video with synchronized audio
35 Y N 7.2 Audio description technology 7.2.1: Audio description playback Condition: Where web content or ICT displays video with synchronized audio
36 Y N 7.2 Audio description technology 7.2.2: Audio description synchronization Condition: Where web content or ICT has a mechanism to play audio description
37 Y N 7.2 Audio description technology 7.2.3: Preservation of audio description Condition: Where web pages or ICT transmit, convert, or record video with synchronized audio
38 Y N 7.3 User controls for captions and audio description 7.3: User controls for captions and audio description Condition: Where web pages or ICT primarily display materials containing video with associated audio content
39 Y N 9.6 WCAG conformance requirements 9.6: WCAG conformance requirements Condition: Only for websites: Where ICT is a web page
40 N Y 11.1 Perceivable 11.1.1.1.2: Non-text content (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
41 N Y 11.1 Perceivable 11.1.2.1.2.1: Pre-recorded audio-only (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
42 N Y 11.1 Perceivable 11.1.2.1.2.2: Pre-recorded video-only (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
43 N Y 11.1 Perceivable 11.1.2.3.2: Audio description or media alternative (pre-recorded – closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
44 N Y 11.1 Perceivable 11.1.3.5.2: Identify input purpose (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
45 N Y 11.1 Perceivable 11.1.4.4.2: Resize text (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
46 N Y 11.1 Perceivable 11.1.4.5.2: Images of text (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
47 N Y 11.2 Operable 11.2.1.1.2: Keyboard (closed funtionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
48 N Y 11.2 Operable 11.2.1.4.2: Character key shortcuts (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
49 N Y 11.3 Understandable 11.3.1.1.2: Language of software (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
50 N Y 11.3 Understandable 11.3.3.1.2: Error Identification (closed functionality) Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface which is closed to assistive technologies for screen reading
51 N Y 11.5 Interoperability with assistive technology 11.5.2.3: Use of accessibility services Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
52 N Y 11.5 Interoperability with assistive technology 11.5.2.5: Object information Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
53 N Y 11.5 Interoperability with assistive technology 11.5.2.6: Row, column, and headers Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
54 N Y 11.5 Interoperability with assistive technology 11.5.2.7: Values Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
55 N Y 11.5 Interoperability with assistive technology 11.5.2.8: Label relationships Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
56 N Y 11.5 Interoperability with assistive technology 11.5.2.9: Parent-child relationships Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
57 N Y 11.5 Interoperability with assistive technology 11.5.2.10: Text Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
58 N Y 11.5 Interoperability with assistive technology 11.5.2.11: List of available actions Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
59 N Y 11.5 Interoperability with assistive technology 11.5.2.12: Execution of available actions Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
60 N Y 11.5 Interoperability with assistive technology 11.5.2.13: Tracking of focus and selection attributes Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
61 N Y 11.5 Interoperability with assistive technology 11.5.2.14: Modification of focus and selection attributes Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
62 N Y 11.5 Interoperability with assistive technology 11.5.2.15: Change notification Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
63 N Y 11.5 Interoperability with assistive technology 11.5.2.16: Modifications of states and properties Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
64 N Y 11.5 Interoperability with assistive technology 11.5.2.17: Modifications of values and text Condition: Only for mobile applications: Where ICT is non-web software that provides a user interface
65 N N 11.6 Documented accessibility usage 11.6.2: No disruption of accessibility features Condition: Where ICT is non-web software that provides a user interface
66 Y N 11.7 User preferences 11.7: User preferences Condition: For web pages: unconditional. For mobile applications: Where ICT is non-web software that is not designed to be isolated from its platform, and that provides a user interface
67 Y N 11.8 Authoring Tools 11.8.1: Content technology Condition: Where web content or ICT is an authoring tool
68 Y N 11.8 Authoring Tools 11.8.2: Accessible content creation Condition: Where web content or ICT is an authoring tool
69 Y N 11.8 Authoring Tools 11.8.3: Preservation of accessibility information in transformations Condition: Where web content or ICT is an authoring tool
70 Y N 11.8 Authoring Tools 11.8.4: Repair assistance Condition: Where web content or ICT is an authoring tool
71 Y N 11.8 Authoring Tools 11.8.5: Templates Condition: Where web content or ICT is an authoring tool
72 Y N 12.1 Product documentation 12.1.1: Accessibility and compatibility features Condition: For web pages and mobile applications (unconditional)
73 Y N 12.1 Product documentation 12.1.2: Accessible documentation Condition: For web pages and mobile applications (unconditional)
74 Y N 12.2 Support services 12.2.2: Information on accessibility and compatibility features Condition: For web pages and mobile applications (unconditional)
75 Y N 12.2 Support services 12.2.3: Effective communication Condition: For web pages and mobile applications (unconditional)
76 Y N 12.2 Support services 12.2.4: Accessible documentation Condition: For web pages and mobile applications (unconditional)

And – please don’t forget to add WCAG to the rows to have the full overview. To not make my table even longer I decided to left out the 50 WCAG success criteria.

Author: Bogdan Cerovac

I am IAAP certified Web Accessibility Specialist (from 2020) and was Google certified Mobile Web Specialist.

Work as digital agency co-owner web developer and accessibility lead.

Sole entrepreneur behind IDEA-lab Cerovac (Inclusion, Diversity, Equity and Accessibility lab) after work. Check out my Accessibility Services if you want me to help your with digital accessibility.

Also head of the expert council at Institute for Digital Accessibility A11Y.si (in Slovenian).

Living and working in Norway (🇳🇴), originally from Slovenia (🇸🇮), loves exploring the globe (🌐).

Nurturing the web from 1999, this blog from 2019.

More about me and how to contact me: