What the standard is for
EN 301 549 is the harmonised standard European legislation points at when it needs a technical definition of accessible. It was written for public procurement and now carries the weight of the Accessibility Act as well. Its job is to turn a legal requirement into testable clauses.
For web content, clause 9 restates the WCAG success criteria with its own numbering, so 9.1.4.3 is WCAG 1.4.3 Contrast (minimum). That numbering is what appears in tenders and audit letters, which is why a finding that only names a tool rule is weaker than one that names the clause.
The standard reaches past the page. If the site behaves like software, clause 11 applies; if it ships documents, clause 12 does; if it offers support channels, those have to be reachable too. A scan alone never covers all of it, and an honest report says which parts were not assessed.
The clauses that touch a website
Clause 9 items map straight onto WCAG success criteria. The last two rows are the ones teams forget until a procurement questionnaire arrives.
| Clause | Requirement | WCAG level | How it is tested |
|---|---|---|---|
| 9.1.1.1 | Non-text content | A | automated |
| 9.1.3.1 | Info and relationships | A | partly automated |
| 9.1.4.3 | Contrast (minimum) | AA | automated |
| 9.2.1.1 | Keyboard | A | manual |
| 9.2.4.3 | Focus order | A | manual |
| 9.2.4.7 | Focus visible | AA | partly automated |
| 9.2.5.8 | Target size (minimum) | AA | automated |
| 9.3.1.1 | Language of page | A | automated |
| 9.4.1.2 | Name, role, value | A | automated |
| 11.x | Software behaviour, where the site is an app | — | manual |
| 12.1.2 | Accessible documentation and support | — | manual |
Where automation stops and a person starts
Clause 9 is partly machine-checkable. Clauses 11 and 12 are not, and pretending otherwise is how an evidence file falls apart under questioning.
Automated testing covers a subset of accessibility barriers. Manual verification is required for a complete assessment.
How Conforma maps findings to clauses
- Every rule carries both references, so one finding reads as 9.1.4.3 for the auditor and 1.4.3 for the developer, with our own short description instead of copied standard text.
- Clause coverage is shown per scan: which clauses automation exercised, which were recorded manually, and which were not assessed at all.
- The statement generator writes the declaration with the correct supervisory body and complaint route per country, and keeps dated versions, because an audit reads the version that was live on the day.
- Raw scanner output is archived with every scan, so a clause-level claim can be traced back to the measurement that produced it.
Questions we get on this
Is EN 301 549 mandatory?
The standard is voluntary, but it is the harmonised standard cited for the Accessibility Act and the Web Accessibility Directive. Following it gives a presumption of conformance; deviating means proving equivalence yourself.
Which clause covers websites?
Clause 9. It mirrors WCAG 2.1 and 2.2 success criteria clause by clause, so 9.2.4.3 is Focus order. Clauses 11 and 12 pick up software behaviour, documents and support channels.
Can a vendor declare conformance for us?
No. The responsible economic operator declares conformance. A vendor supplies the measurement, the trail and the archive behind it, which is exactly the line our terms hold.