WCAG: is it sufficient for the European Accessibility Act?

WCAG (Web Content Accessibility Guidelines) is an international standard for web accessibility, and as such is well known and widely used. Many accessibility audits are carried out in Luxembourg based on WCAG. Is this sufficient to meet the requirements of the European Accessibility Act? That is what we propose to explore with you in this article.

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The legal and regulatory context

In Luxembourg, the European Accessibility Act has been transposed into law on March 8, 2023. To support the legal requirements, the European Union has mandated the creation or updating of six standards that will be applicable throughout Europe in the coming months. A standard is much more precise than a law and makes it possible to prove compliance with legal requirements. This is known as the presumption of conformity: if the applicable standard(s) are complied with, then compliance with the legal requirements is presumed.

The subjects covered by these standards are very broad, ranging from the built environment for self-service terminals to non-digital information and support services. One standard is particularly important when dealing with a service that is delivered in the form of a website, mobile application, or self-service terminal: EN 301 549 "accessibility requirements for ICT products and services." This standard has been in existence since 2014 and is already in force throughout Europe under the Web Accessibility Directive (transposed into law on May 28, 2019) for public sector websites and apps. It is currently in version 3.2.1 and will be updated in the second half of 2026 with a new version to support all the requirements of the European Accessibility Act.

Depending on the service, you may need to apply the requirements of several standards. For example, for an e-commerce website that offers a support service feature, it will be necessary to comply with standard EN 301 549 as well as the standard on support services.

How can you audit the accessibility of a website or web application?

The international standard WCAG often comes to mind when it comes to web accessibility. It is important to note that WCAG 2.1 is included in its entirety in the European standard EN 301 549 in Chapter 9.

However, this European standard goes further, and testing WCAG alone is not enough. WCAG is only applicable to web content and represents 36% of all criteria applicable in EN 301 549.

For non-web content (e.g., PDF, Word, Excel, etc.), chapter 10 of the standard is applicable and is based on WCAG2ICT, an adaptation of WCAG for non-web software and documents. This part represents 33% of the EN 301 549 criteria applicable to websites.

Other criteria specific to the European standard do not exist at all in the WCAG universe and must also be tested if they are applicable. They represent 31% of the criteria applicable to a website.

Here are some examples of criteria from the European standard that are not part of WCAG:

  • On video players, it must be as easy to activate subtitles or audio description as it is to pause the video (criterion 7.3).
  • If your site offers a publicly available editing tool, such as a comment section with a rich editor, this editing tool must allow the creation of accessible content (criterion 11.8).
  • If you have a login or electronic signature system that uses biometrics, an alternative must be provided that is not based on biometrics, or that is based on another biological characteristics. (criterion 5.3)

These are just a few examples of non-WCAG criteria that are part of the European standard. Please refer to the standard for more information.

Table A.1 of version 3.2.1 of the standard lists the criteria applicable to a website or web application. The next version of the standard will include more detailed correspondence tables in the appendix regarding the requirements of the European Accessibility Act.

If you evaluate the accessibility of your website based on WCAG alone, you are only testing about one-third of the applicable criteria in the European standard, which is not sufficient to meet the requirements of the European Accessibility Act.

How can you audit the accessibility of a mobile application?

WCAG is only applicable to web content. It is therefore not recommended to conduct a WCAG compliance audit of a mobile application.

Applications are subject to the "software" criteria in Chapter 11 of the standard, based on WCAG2ICT, which represent 27% of the criteria applicable to mobile applications.

If your app contains non-web documents, the criteria in Chapter 10, also based on WCAG2ICT, are applicable and represent 28% of all criteria applicable to mobile applications.

Finally, the criteria specific to the standard represent 45% of the criteria applicable to mobile applications.

You will find the criteria applicable to a mobile application in Table A.2 of version 3.2.1 of the standard.

How can you assess the accessibility of a website or mobile application in practical terms?

Since 2020, the Luxembourg government has been offering accessibility testing frameworks available on the website accessibilite.public.lu. These frameworks provide a testing method and operational framework for effectively testing the accessibility of a website, mobile application, or PDF document. They are available in French and English. It is not mandatory to follow these frameworks; they are simply an additional tool at your disposal for assessing accessibility.

In summary

Testing a website based on WCAG is not sufficient to meet all the requirements of the European Accessibility Act. We therefore recommend that you carry out your audits based on the EN 301 549 standard.

This standard will be updated in 2026, so please follow our news to be notified of its release.

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