WCAG and EN 301 549
WCAG describe what makes digital content usable for people with disabilities. The European standard EN 301 549 applies these requirements to websites, software and documents. Here you can read how the two relate and where PDF/UA comes in.
General overview. This page summarises the basics in simplified form. It is a draft and is currently under expert review. The original texts of the guidelines and the standard are authoritative.
WCAG: four principles, three levels
The Web Content Accessibility Guidelines (WCAG) are published by the World Wide Web Consortium (W3C). Version 2.1 appeared in 2018 and version 2.2 in 2023. The guidelines are technology-neutral and organised into testable success criteria that follow four principles:
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Perceivable
Information is presented so that everyone can perceive it, for example through alternative text for images or sufficient contrast.
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Operable
All functions can be operated, including by keyboard; in PDFs, for example, links and form fields.
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Understandable
Content and operation are understandable, for example through a declared language and clear labels.
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Robust
Assistive technologies can read content reliably; in PDFs mainly through a correct tag structure.
The three conformance levels
- Level A
- Basic requirements.
- Level AA
- The usual benchmark in Europe; EN 301 549 and the laws generally refer to this level.
- Level AAA
- Further requirements that cannot be met for all content. The W3C does not recommend them as a general requirement for entire sites or services.
EN 301 549: the European standard
EN 301 549 is published jointly by the European standardisation organisations CEN, CENELEC and ETSI. It sets accessibility requirements for information and communication technology as a whole: websites, software, hardware, documents, and documentation and support.
Version V3.2.1 of 2021 serves as the harmonised standard for Directive (EU) 2016/2102. A revised version intended to cover the European Accessibility Act as well is in preparation (as of October 2026).
For PDFs, chapter 10 is the relevant part. It applies the WCAG level A and AA success criteria to documents, with adaptations. Some criteria that only make sense for sets of web pages, such as multiple ways to reach a page, do not apply to single documents.
Structure (selection)
- Chapter 9
- Web
- Chapter 10
- Documents that are not web pages, such as PDFs
- Chapter 11
- Software
- Chapter 12
- Documentation and support
How WCAG, EN 301 549 and PDF/UA fit together
Put simply: WCAG describe what users need. EN 301 549 turns this into a European standard that laws build on. PDF/UA describes how a PDF can implement these requirements technically.
WCAG, EN 301 549 and PDF/UA compared
| Aspect | WCAG | EN 301 549 | PDF/UA |
|---|---|---|---|
| Publisher | W3C | CEN, CENELEC and ETSI | ISO |
| Scope | Web content, technology-neutral | Information and communication technology as a whole, including documents | PDF documents and the software that processes them |
| Type of requirements | Success criteria: what should be achieved | Requirements per technology, for web and documents largely taken from WCAG | Technical rules for how the file is built |
| Role in law | Usually incorporated via EN 301 549 | Harmonised standard for public bodies; widely used for orientation under the BFSG | Not referred to directly by BITV 2.0 or the BFSG; a widely used technical benchmark |
| Checking | Partly automatic; many criteria only by people | As for WCAG, plus further requirements | Partly automatic (e.g. veraPDF), partly by people (Matterhorn Protocol) |
Simplified comparison; the original texts are authoritative. More on the PDF standard on the PDF/UA page.
Guidance for PDFs
- Set the target: the benchmark is usually WCAG 2.1 level AA, as applied to documents by chapter 10 of EN 301 549.
- Implement it technically: in a PDF this is usually done according to PDF/UA: tags, reading order, alternative text, language and metadata.
- Consider the design: some criteria concern design and content, such as colour contrast, meaningful link text or colour as the only distinguishing feature. These are decided when the document is created.
- Check and document: automated checks cover only part of it. Plan for human review and record open points.
What EqualDoc takes care of
EqualDoc remediates existing PDFs according to PDF/UA and checks the result against the machine-checkable requirements of PDF/UA and EN 301 549. It keeps the original’s appearance wherever possible; design questions such as colour contrast belong to document creation. The report lists what needs human judgement.
Frequently asked questions
Which WCAG version applies?
EN 301 549 V3.2.1 refers to WCAG 2.1. The newer WCAG 2.2 adds some criteria; whether and when the standard adopts them depends on its revision. If you create new content today, you can already work towards WCAG 2.2.
Do WCAG apply to PDFs at all?
WCAG were written for web content. EN 301 549 expressly applies their criteria to documents in chapter 10, and the W3C publishes dedicated techniques for PDF.
Do I have to meet level AAA?
Usually not. Legal requirements in Europe mostly refer to level AA. Individual AAA criteria can still be worthwhile.
Is EN 301 549 the same as BITV 2.0?
No. BITV 2.0 is a German regulation; EN 301 549 is a European standard. BITV 2.0 refers to harmonised standards, in practice EN 301 549, but also has requirements of its own, for example on Easy Language and sign language. More on the Public sector page.
Check your PDF against PDF/UA and EN 301 549
EqualDoc remediates PDFs automatically and checks the result against the machine-checkable requirements. Anything that needs human judgement is listed in the report. EqualDoc issues no certificates.