EAA vs WCAG: Understanding the Standards
The alphabet soup of accessibility standards can be confusing. EAA, EN 301 549, WCAG 2.1, WCAG 2.2 — how do they all fit together? Here's the clear explanation.
The Hierarchy: Law → Standard → Guidelines
Think of it as a pyramid. At the top is the law (what you must do), in the middle is the standard (how compliance is measured), and at the base are the technical guidelines (the specific requirements).
European Accessibility Act (EAA)
EU Directive 2019/882. The law that requires digital products and services sold to EU consumers to be accessible. It defines what must be accessible and who must comply, but doesn't specify the technical details.
EN 301 549
The European harmonized standard for ICT accessibility. It defines how compliance is measured and provides the technical requirements. The EAA references this standard. EN 301 549 covers web, documents, software, and hardware.
WCAG 2.1 / 2.2
Web Content Accessibility Guidelines from W3C. The specific technical criteria for making web content accessible. EN 301 549 Chapter 9 (Web) incorporates WCAG 2.1 Level AA. WCAG 2.2 is the latest version and is backwards compatible.
Side-by-Side Comparison
| Aspect | EAA | EN 301 549 | WCAG |
|---|---|---|---|
| Type | EU Law (Directive) | European Standard | W3C Guidelines |
| Scope | Digital products & services to consumers | Web, documents, software, hardware | Web content only |
| Geographic Application | EU member states | EU (and often referenced globally) | Global (W3C) |
| Enforcement | National regulators (fines, market removal) | Presumption of conformity | Referenced by laws |
| Current Version (Web) | N/A (references EN 301 549) | v3.2.1 (2021) | 2.2 (2023) |
| WCAG Level Required | Via EN 301 549 | WCAG 2.1 Level AA | A, AA, or AAA |
Which Version of WCAG Should I Follow?
The Short Answer
Target WCAG 2.2 Level AA. Here's why:
- EN 301 549 currently references WCAG 2.1 Level AA, so that's the legal minimum for EAA compliance.
- WCAG 2.2 is backwards compatible with 2.1 — if you meet 2.2, you automatically meet 2.1.
- EN 301 549 is expected to update to reference WCAG 2.2 in a future revision.
- WCAG 2.2 adds 9 new success criteria that improve accessibility for cognitive disabilities, low vision, and mobile users.
WCAG 2.1 → 2.2 Changes
WCAG 2.2 adds these criteria (all AA or A):
- +2.4.11 Focus Not Obscured (AA)
- +2.5.7 Dragging Movements (AA)
- +2.5.8 Target Size (Minimum) (AA)
- +3.2.6 Consistent Help (A)
- +3.3.7 Redundant Entry (A)
- +3.3.8 Accessible Authentication (AA)
- -4.1.1 Parsing (removed)
Practical Implications
- Focus Not Obscured: Sticky headers shouldn't cover focused elements
- Dragging Movements: Drag-and-drop needs single-click alternatives
- Target Size: Touch targets minimum 24x24 CSS pixels
- Accessible Auth: Don't require CAPTCHAs without alternatives
EN 301 549 Clause Mapping
EN 301 549 Chapter 9 covers web content. The clause numbers directly correspond to WCAG success criteria:
The pattern is simple: EN 301 549 clause 9.X.Y.Z corresponds to WCAG X.Y.Z
Frequently Asked Questions
If I comply with WCAG 2.2, am I automatically EAA compliant?
For web content, yes — meeting WCAG 2.2 Level AA means you meet the web requirements of EN 301 549, which gives you presumption of conformity with the EAA. However, the EAA also requires an accessibility statement and may have additional requirements for non-web components (mobile apps, documents, etc.).
Does the EAA apply to websites outside the EU?
Yes, if you sell digital products or services to EU consumers. The EAA applies based on where your customers are, not where your business is located. A US company selling to Dutch customers must comply with the EAA for that service.
What about WCAG 2.0? Is that still relevant?
WCAG 2.0 is outdated. EN 301 549 requires WCAG 2.1 Level AA as the minimum. Since WCAG 2.2 is backwards compatible with 2.1, targeting 2.2 is recommended. You should not target WCAG 2.0 for new compliance efforts.
Is Level AAA required?
No. EN 301 549 and the EAA require Level AA. Level AAA is not required by any major legislation. Some AAA criteria are difficult to achieve for all content types. However, implementing AAA criteria where practical improves accessibility further.
What about Section 508 and ADA?
Section 508 is US law for federal agencies (recently updated to reference WCAG 2.0 Level AA). The ADA applies to businesses in the US and courts have referenced WCAG as the standard. If you need to comply with both US and EU requirements, targeting WCAG 2.2 Level AA covers both.
Continue Learning
Explore related guides to deepen your understanding of accessibility standards.
EAA Compliance Checklist
EN 301 549 Chapter 9 web requirements mapped to WCAG 2.2 criteria.
European Accessibility Act
What US and UK businesses need to know about the EAA in 2026.
EN 301 549 Guide
The European accessibility standard explained with chapter breakdowns.
WCAG 2.2 AA Checklist
All 50 Level A and AA success criteria with testing indicators.
Ready to Check Your Compliance?
inclly scans your website against WCAG 2.2 and maps results to EN 301 549 clauses. See exactly which requirements you meet and what needs to be fixed.