EAA vs WCAG

Three documents, three roles

The European Accessibility Act

Directive (EU) 2019/882. A law, transposed into each member state's legislation, with its own authority and penalties per country. It defines which products and services must be accessible and states the requirements in functional terms, such as making websites and apps perceivable, operable, understandable and robust. It does not set pixel-level technical tests. See the full EAA guide.

EN 301 549

The harmonised European standard for accessibility requirements for ICT products and services. Broader than WCAG, since it also covers hardware, documentation and support services, but for web and software content it incorporates WCAG success criteria. This is the bridge: the standard used to show what meeting the EAA's requirements looks like in practice.

WCAG

The Web Content Accessibility Guidelines, published by the W3C. A technical standard with testable success criteria organised into levels A, AA and AAA. It has no enforcement mechanism of its own; failing WCAG is not illegal anywhere unless a law points to it.

Which WCAG version counts, as of September 2026

In September 2026 a new version of the standard, EN 301 549 v4.1.1, was published. It adopts WCAG 2.2 as the benchmark for websites, software and digital documents, replacing WCAG 2.1, and adds an annex that links its requirements directly to the EAA.

That does not change the legal position yet. The European Commission's AccessibleEU centre is explicit that the new version is not yet the legal reference standard for demonstrating compliance with the EAA or the Web Accessibility Directive. Until the Commission formally cites v4.1.1 in the Official Journal of the European Union, the reference remainsEN 301 549 v3.2.1 (2021), based on WCAG 2.1 Level AA.

AccessibleEU gives no date for that citation. If you read a specific month elsewhere, treat it as a forecast rather than a schedule.

Source: AccessibleEU (European Commission), "The European accessibility standard EN 301 549 has been updated", 7 September 2026.

Why you should build to WCAG 2.2 anyway

The W3C states that the WCAG 2.0 and 2.1 success criteria are essentially the same in 2.2, with one exception: 4.1.1 Parsing was removed as obsolete. So work done to WCAG 2.2 covers the 2.1 criteria that are still in force, and you are not building twice when the reference changes. The difference is the criteria WCAG 2.2 adds.

Nine criteria are new in WCAG 2.2. Three are at level AAA, above the Level AA the current reference is based on. The six at levels A and AA are the ones that matter, and several land squarely on an online store:

Two of these deserve attention because they overlap with what the EAA asks of e-commerce specifically. Annex I of the Directive requires identification, security and payment functionality to be accessible, and 3.3.8 Accessible Authentication is where a login or a verification step fails that in practice. 3.3.7 Redundant Entry is aimed squarely at checkouts that ask for the same address twice. See EAA for e-commerce.

Source: W3C, What's New in WCAG 2.2. The store examples are our illustrations of each criterion, not W3C text.

What passing WCAG does and does not prove

• It is the closest practical proxy for the technical bar a website has to meet under the EAA. It is not the legal text itself.
• An automated scan tests only part of WCAG. Automated testing typically catches an estimated 20–50% of real accessibility issues. Whether alt text is meaningful, whether focus order makes sense and whether an error message is helpful all need a person.
• Legal compliance involves more than the website. Whether your service is in scope, your national transposition, the accessibility information you must publish under Article 13, and whether an exemption applies are all separate questions from WCAG conformance.