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 explains functional performance needs, clauses 5 to 13 contain technical requirements for ICT, clause 14 explains conformance logic, Annex B links requirements to user needs, and Annex C gives procedures for checking individual requirements. Use those parts as evidence labels in the EAA file.

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.

Use this mapping as a minimum evidence index. It is not a statement that every listed clause applies to every product or service; EN 301 549 requirements are self-scoping except for documentation and support services in clause 12.

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.

A useful clause map is a table, not a narrative memo. Each row should let a reviewer trace an EAA requirement to a tested ICT clause or to a documented non-ICT evidence record. Keep the table versioned because EN 301 549 conformance can be affected by implementation or maintenance changes, and ETSI describes a planned update to support Directive (EU) 2019/882.

Do not claim that an EN 301 549 row creates EAA presumption of conformity unless the relevant harmonised standard or part has been cited for the EAA requirement in the Official Journal and the row is within the scope of that citation. If the team cannot verify that citation from official sources, phrase the row as implementation evidence rather than legal presumption.