EU Accessibility Act EN 301 549 clause mapping

Build the mapping in this order: covered EAA product or service, Annex I requirement, ICT feature or content type, applicable EN 301 549 clause, test result, and residual EAA evidence. This avoids the common mistake of starting with a WCAG or EN 301 549 checklist and assuming it covers packaging, service terms, built-environment context, Article 14 assessments, or national authority evidence.

For ICT products and services, EN 301 549 gives a practical clause structure. Clause 4 contains functional performance statements, clauses 5 to 13 contain technical requirements for ICT, clause 14 defines conformance with the standard, Annex B links requirements to functional performance statements, and Annex C gives procedures for checking individual requirements. Use those parts as evidence labels in the EAA file.

Keep the legal status separate from the technical map. V3.2.1 supports Directive (EU) 2016/2102, the Web Accessibility Directive. ETSI lists V4.1.0 (2026-06), which adds EAA mappings and substantial clause changes, as on approval. An approval-stage text is not a final standard or an Official Journal reference. A V3.2.1 test can still be useful EAA evidence, but Annex A of that edition does not itself map the EAA or create an EAA presumption of conformity.

The clause map should be feature-based, because EN 301 549 is organised by ICT functions and product features rather than by EAA commercial categories. A banking app, e-commerce checkout, ticketing terminal, e-reader, or customer-support portal can therefore draw evidence from several clauses at once.

This mapping is a minimum evidence index. It is not a statement that every listed clause applies to every product or service. Most EN 301 549 requirements contain a precondition that determines applicability; clause 12 applies to documentation and support services where those materials or services are provided.

EN 301 549 can support many ICT controls, but the EAA file still needs evidence that the actual product or service meets the Directive's Annex I outcomes. Keep separate rows for information provided with the product, instructions, packaging where relevant, service information, websites and mobile apps, support services, sector-specific service functions, and Article 14 exception records.

For products, the technical documentation must show the applicable accessibility requirements, the design, manufacture, and operation evidence, harmonised standards applied in full or in part, and the solutions used where standards were not applied. For services, the provider's information must describe the service, explain its operation, and describe how relevant Annex I requirements are met.

Use a table so each row lets a reviewer trace an EAA requirement to a tested ICT clause or a documented non-ICT evidence record. Version the table because a product release, content change, support-process change, or new standard edition can change the result.

Do not claim that an EN 301 549 row creates an EAA presumption of conformity unless the relevant standard or part has been cited in the Official Journal for Directive (EU) 2019/882 and the row falls within the cited coverage. A citation for the Web Accessibility Directive does not transfer that legal effect to the EAA. If the team cannot verify the EAA citation and its conditions from official sources, describe the row as technical implementation evidence.