Accessibility: European Accessibility Act, EN 301 549
Applicable since June 28, 2025, the directive Directive (EU) 2019/882 known as the European Accessibility Act (EAA) sets accessibility requirements for a closed list of products and services. For electronics manufacturers it is a CE marking directive: Annex I requirements, Annex IV self-assessment, technical documentation and an EU declaration of conformity. The reference standard EN 301 549 changed edition in September 2026: V4.1.1 follows WCAG 2.2 instead of WCAG 2.1 and is the first edition mapped to the EAA, but it is not yet cited in the Official Journal under the directive. This guide follows the article numbers of the text itself.
Key dates
Section titled “Key dates”| Date | Event | Source |
|---|---|---|
| April 17, 2019 | Directive (EU) 2019/882 adopted | Directive, signature |
| June 7, 2019 | Published in OJ L 151, p. 70 | Official Journal |
| June 27, 2019 | Entry into force (twentieth day after publication) | Article 34 |
| June 28, 2022 | Transposition deadline | Article 31(1) |
| September 14, 2022 | Standardisation request C(2022) 6456 (M/587) to CEN, CENELEC and ETSI | Implementing Decision |
| March 9, 2023 | France: Article 16 of loi 2023-171 creates Article L. 412-13 of the consumer code | Loi 2023-171 |
| October 9, 2023 | France: decree 2023-931 (Articles D. 412-49 to D. 412-62, R. 451-4) and the order setting the requirements | Légifrance |
| June 28, 2025 | National measures apply; products placed on the market after this date are covered | Articles 2(1), 31(2) |
| September 15, 2025 | Deadline set by M/587, as adopted, for the revised EN 301 549 | M/587, Annex I, Table 2 |
| August 24, 2026 | EN 301 549 V4.1.1 adopted, published as the 2026-09 edition | V4.1.1, foreword |
| November 30, 2026 | V4.1.1: latest date of announcement (doa) | V4.1.1, foreword |
| May 31, 2027 | V4.1.1: latest date of national publication (dop/e) | V4.1.1, foreword |
| June 28, 2027 | Latest date a Member State may defer the 112 answering obligations of Article 4(8) | Article 31(3) |
| May 31, 2028 | V4.1.1: withdrawal of conflicting national standards (dow) | V4.1.1, foreword |
| June 28, 2030 | End of the transitional period for services using products already in use; first Commission report | Articles 32(1), 33(1) |
The national dates of V4.1.1 (doa, dop, dow) govern the withdrawal of national standards. They do not create a presumption of conformity under the EAA: only an Official Journal citation does.
Scope: the closed list of Article 2
Section titled “Scope: the closed list of Article 2”Products (Article 2(1))
Section titled “Products (Article 2(1))”The directive applies to the following products placed on the market after June 28, 2025:
| Article 2(1) | Product | What the recitals and definitions add |
|---|---|---|
| (a) | Consumer general purpose computer hardware systems and their operating systems | Article 3(39) names desktops, notebooks, smartphones and tablets. Recital 25: specialised computers embedded in consumer electronics are not such systems, and single components (mainboard, memory chip) are not covered individually. BIOS, boot loaders and boot firmware are outside the operating system definition (Article 3(38)) |
| (b)(i) | Payment terminals | Hardware and software (recital 26) |
| (b)(ii) | ATMs, ticketing machines, check-in machines, interactive self-service information terminals dedicated to services covered by the directive | Terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock are excluded |
| (c) | Consumer terminal equipment with interactive computing capability used for electronic communications services | Recital 30: includes equipment used to set up access, such as a router or a modem |
| (d) | Consumer terminal equipment with interactive computing capability used for accessing audiovisual media services | Recital 31 cites set-top box applications and connected television services among the related services |
| (e) | E-readers | Hardware and software (Article 3(42)) |
Services (Article 2(2)) and exclusions (Article 2(4))
Section titled “Services (Article 2(2)) and exclusions (Article 2(4))”The services provided to consumers after June 28, 2025 are: electronic communications services (except transmission services used for machine-to-machine services), services providing access to audiovisual media services, listed elements of air, bus, rail and waterborne passenger transport services, consumer banking services, e-books and dedicated software, and e-commerce services. Article 2(3) adds the answering of emergency communications to 112.
For website and mobile application content, Article 2(4) excludes pre-recorded time-based media and office files published before June 28, 2025, online maps when the essential information is accessible, third-party content neither funded, developed nor controlled by the operator, and archives not updated after June 28, 2025.
Annex I: which section applies to what
Section titled “Annex I: which section applies to what”Article 4 does not apply the whole of Annex I to everything. The split is per section:
| Annex I section | Content | Applies to | Article |
|---|---|---|---|
| Section I | Information on use, user interface and functionality, support services | All products | 4(2), first subparagraph |
| Section II | Accessible packaging and installation, maintenance, storage and disposal instructions | All products except self-service terminals | 4(2), second subparagraph |
| Section III | General requirements for services | All services except urban, suburban and regional transport | 4(3) |
| Section IV | Service-specific requirements | All services | 4(3) |
| Section V | Answering emergency communications to 112 | Most appropriate PSAP | 4(8) |
| Section VI | Features meeting accessibility obligations in other Union acts | Presumption under Article 24(2) | 24 |
| Section VII | Functional performance criteria | Functions not addressed by Sections I to VI | Annex I |
Annex II gives indicative, non-binding examples of solutions. Member States may inform operators of them (Article 4(7)).
Section I point 2(o): the sector-specific product requirements
Section titled “Section I point 2(o): the sector-specific product requirements”Point 2 of Section I lists general user-interface requirements (a) to (n): more than one sensory channel, alternatives to speech, flexible magnification and contrast, alternatives to colour and to audible signals, user control of volume and speed, alternatives to fine motor control, no extensive reach or great strength, no photosensitive seizure triggers, privacy when using accessibility features, an alternative to biometrics, enough time, and interfaces to assistive technologies. Point 2(o) then adds, per product type:
| Point 2(o) | Product | Requirement (Annex I text) | EN 301 549 V4.1.1 clauses mapped in Annex ZB |
|---|---|---|---|
| (i) | Self-service terminals | Text-to-speech; personal headsets; timed responses signalled through more than one sensory channel, with the possibility to extend time; adequate contrast and tactilely discernible keys; no need to activate an accessibility feature to turn it on; compatibility with hearing technologies (hearing aids, T-coils, cochlear implants, assistive listening devices) when audio is used | Hearing technologies row: 4.2, 5.1, 8.2, 11.5.2 |
| (ii) | E-readers | Text-to-speech | Annex ZB, Table ZB.2 |
| (iii) | Communications terminal equipment | Real-time text when text capability exists alongside voice, high fidelity audio; total conversation when video exists; effective wireless coupling to hearing technologies; no interference with assistive devices | Wireless coupling row: 4.2.4, 4.2.5, 8.2.2 |
| (iv) | Audiovisual media access equipment | Make available the accessibility components supplied by the media service provider, for access, selection, control, personalisation and transmission to assistive devices | Annex ZB, Table ZB.2 |
Clause 8.2.2.2 of V4.1.1 requires a wireless device held to the ear, with speech output, to provide magnetic coupling and reduced interference to hearing technologies meeting ETSI ES 200 381-2, and notes that ICT meeting ANSI/IEEE C63.19 is deemed to comply with that clause. The US side is covered in hearing aid compatibility (HAC).
EN 301 549: editions and legal status
Section titled “EN 301 549: editions and legal status”EN 301 549 is published jointly by ETSI, CEN and CENELEC. The V4.1.1 foreword states that it was produced by ETSI Technical Committee Human Factors (HF).
| Edition | Date | WCAG baseline | Prepared under | Official Journal citation |
|---|---|---|---|---|
| V3.2.1 | March 2021 (2021-03) | WCAG 2.1 | C(2017) 2585 (M/554), Directive (EU) 2016/2102 | Directive (EU) 2016/2102, Implementing Decision (EU) 2021/1339 |
| V4.1.1 | September 2026 (2026-09), adopted August 24, 2026 | WCAG 2.2 (clauses 9, 10, 11) | C(2022) 6456 (M/587), Directive (EU) 2019/882 | None found under Directive (EU) 2019/882 as of October 7, 2026 |
The V4.1.1 foreword lists the significant changes from V3.2.1: real-time text requirements of clause 6.2 revised and extended to total conversation, clauses 9 to 11 aligned with WCAG 2.2, a new Annex ZA for Directive (EU) 2016/2102, a new Annex ZB for Directive (EU) 2019/882, and a new clause A.2 with five tables (web page, non-web document, non-web software, hardware, all ICT) to evaluate a specific product or service against the EAA. Annex ZC covers the Section VI link to other Union acts.
Structure of V4.1.1
Section titled “Structure of V4.1.1”| Clause | Title |
|---|---|
| 4 | Functional performance (functional performance criteria; V3.2.1 called them statements) |
| 5 | Generic requirements |
| 6 | ICT supporting real-time bidirectional communication (V3.2.1: ICT with two-way voice communication) |
| 7 | ICT with video capabilities (subtitles, audio description) |
| 8 | Hardware (including 8.2.2 magnetic coupling and 8.3 stationary ICT) |
| 9 | Web |
| 10 | Non-web documents |
| 11 | Non-web software (V3.2.1: Software) |
| 12 | Information about products and services (V3.2.1: Documentation and support services) |
| 13 | ICT providing relay or emergency service access |
| 14 | Conformance |
What "harmonised" means here
Section titled “What "harmonised" means here”Article 15(1) presumes conformity only for harmonised standards whose references are published in the Official Journal. V4.1.1 says the same thing about itself: the presumption applies once it is cited under Directive (EU) 2019/882. Where no reference is published, Article 15(3) lets the Commission adopt technical specifications by implementing act; none has been adopted. Until a citation appears, Annex IV point 2(b) requires the technical documentation to describe the solutions adopted to meet each applicable requirement. Applying V4.1.1 clause by clause, with clause A.2 as the checklist, is the most defensible way to write that description.
M/587 also asked for new harmonised standards on non-digital product information and on support services (deadline March 15, 2026 as adopted) and on emergency communications (January 15, 2027), and for revisions of EN 17161 and EN 17210. Check their status before relying on them.
Conformity route and CE marking
Section titled “Conformity route and CE marking”Annex IV, internal production control
Section titled “Annex IV, internal production control”Article 7(2) sends the manufacturer to Annex IV, an internal production control procedure with no notified body. The manufacturer:
- Designs and manufactures the product in line with the applicable Annex I sections (Article 7(1)).
- Draws up technical documentation that specifies only the applicable requirements and contains at least a general description of the product and the list of cited harmonised standards and technical specifications applied, or, where none was applied, a description of the solutions adopted (Annex IV point 2). Where Article 14 is relied on, the documentation demonstrates the fundamental alteration or disproportionate burden.
- Draws up the EU declaration of conformity, which states that the applicable requirements are met and names any requirement set aside under Article 14 (Article 16(1)). Where several Union acts apply, a single declaration covers all of them (Article 16(3)).
- Affixes the CE marking (Article 17, Annex IV point 4.1).
- Keeps the technical documentation and the declaration for five years after placing on the market (Article 7(3)).
Article 7 also requires a type, batch or serial number, the name and contact address of the manufacturer, and instructions and safety information in a language easily understood by end users. A manufacturer that finds a non-conformity takes corrective action, informs the competent authorities and keeps a register of non-compliant products and related complaints (Article 7(8)).
Economic operators
Section titled “Economic operators”Importers (Article 9) check that the manufacturer applied Annex IV, drew up the documentation and affixed the CE marking. Distributors (Article 10) check the CE marking, the documents and the language of the instructions. An importer or distributor that places the product under its own name or trademark, or modifies it in a way that may affect compliance, becomes the manufacturer (Article 11).
Fundamental alteration and disproportionate burden (Article 14)
Section titled “Fundamental alteration and disproportionate burden (Article 14)”| Article 14 | Rule |
|---|---|
| 14(1) | Requirements apply only as far as they do not cause a fundamental alteration of the basic nature of the product or service, nor a disproportionate burden |
| 14(2) | The operator carries out the assessment; disproportionate burden is assessed against Annex VI (net cost of compliance against overall costs and against net turnover, estimated benefit for persons with disabilities) |
| 14(3) | The assessment is documented and the results kept for five years from the last making available of the product or the last provision of the service |
| 14(4) | Microenterprises dealing with products need not document it, but must give the relevant facts if the authority asks |
| 14(5) | Service providers renew the assessment when the service changes, when asked, and at least every five years |
| 14(6) | No disproportionate-burden defence for an operator that received public or private funding to improve accessibility |
| 14(8) | The operator informs the market surveillance authority of the Member State concerned; not required of microenterprises |
Microenterprises
Section titled “Microenterprises”A microenterprise employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding EUR 2 million (Article 3(23)). Article 4(5) exempts microenterprises providing services from the service requirements. There is no equivalent exemption for products: a microenterprise placing a smartphone or a payment terminal on the market meets Annex I and only benefits from the lighter Article 14 duties above.
Market surveillance, penalties and the transitional period
Section titled “Market surveillance, penalties and the transitional period”Article 19 applies the market surveillance articles of Regulation (EC) No 765/2008 to products. Those articles were deleted by Regulation (EU) 2019/1020, whose Article 39 states that references to them are read as references to Regulation (EU) 2019/1020. When an operator relied on Article 14, the authority checks that the assessment was made, reviews it and its results, including the correct use of the Annex VI criteria, and checks compliance with the applicable requirements (Article 19(2)). Non-compliant products can lead to corrective action, restriction, withdrawal or recall; see market surveillance and RAPEX.
Member States lay down penalties that are effective, proportionate and dissuasive and that take into account the seriousness of the non-compliance, the number of non-compliant units and the number of persons affected (Article 30). Article 29 requires that consumers, and bodies with a legitimate interest, can take action before courts or administrative bodies.
Article 32 is about services, not about stock on shelves: until June 28, 2030 service providers may keep providing their services with products they lawfully used before that date, service contracts agreed before June 28, 2025 may run unchanged for at most five years from that date, and Member States may allow self-service terminals already in use before June 28, 2025 to stay in service until the end of their economically useful life, up to 20 years after entry into use.
France: how the directive was transposed
Section titled “France: how the directive was transposed”Article 16 of loi 2023-171 of March 9, 2023 created Article L. 412-13 of the consumer code. Decree 2023-931 of October 9, 2023 added Articles D. 412-49 to D. 412-62 (scope, obligations, Article 14 mechanism) and Article R. 451-4, which punishes listed breaches (CE marking, placing on the market without the assessment, failure to provide the declaration or documentation, non-compliance with the requirements) with fines for fifth-class contraventions. A separate order of October 9, 2023 sets out the accessibility requirements applicable to products and services. Article 3 of the decree applies it to products placed on the market and services provided after June 28, 2025.
Design checklist mapped to Annex I
Section titled “Design checklist mapped to Annex I”| Annex I, Section I | What it means at design stage |
|---|---|
| 1(a) | Information on the product itself (labels, warnings) through more than one sensory channel, adequate font size, sufficient contrast |
| 1(b)(vii) to (ix) | Instructions describe the user interface and the accessibility functions point by point, and list the assistive devices tested with the product |
| 2(a), (e) | No function that depends on a single sense; alternatives to audible signals |
| 2(c), (f) | Flexible magnification, brightness and contrast |
| 2(d) | Never convey information by colour alone |
| 2(g) | User control of volume and speed |
| 2(h), (i) | Sequential control, no simultaneous actions, tactile discernible parts, no great reach or strength |
| 2(l) | An alternative to biometric identification |
| 2(m) | Enough and flexible time for interaction |
| 2(n) | Software and hardware interfaces to assistive technologies |
| 3 | Support services give accessibility information in accessible modes |
| Section II | Packaging and installation, maintenance, storage and disposal instructions accessible (all products except self-service terminals) |
Fold this matrix into the technical documentation file and the test plan, and record for each row the EN 301 549 clause tested or the solution adopted.
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim | What the text says |
|---|---|
| "Annex I lists the products in scope." | Article 2(1) lists the products. Annex I sets the requirements, split by section (Article 4). |
| "EN 301 549 is the harmonised standard of the EAA, so applying it gives presumption." | Article 15(1) requires an Official Journal citation under Directive (EU) 2019/882. V3.2.1 is cited only under Directive (EU) 2016/2102, and V4.1.1 states the presumption starts once it is cited under the EAA. |
| "V4 is still a draft." | EN 301 549 V4.1.1 was adopted on August 24, 2026 and published as the 2026-09 edition. |
| "Microenterprises get a lighter regime for products." | Article 4(5) exempts only microenterprises providing services. For products, Article 14(4) and 14(8) only lift the duty to document and notify an Article 14 assessment. |
| "Products placed on the market before June 28, 2025 may stay in service until 2030." | Article 32(1) lets service providers keep using products they lawfully used before that date to provide similar services until June 28, 2030. The directive simply does not cover products placed on the market before June 28, 2025 (Article 2(1)). |
| "The disproportionate-burden assessment must be reviewed periodically." | The at-least-every-five-years renewal in Article 14(5) applies to service providers. For products, the assessment is kept for five years from the last making available (Article 14(3)). |
| "Only public accessibility funding blocks the disproportionate-burden defence." | Article 14(6) covers funding from any source other than the own resources of the operator, public or private, provided to improve accessibility. |
| "Every smart device with a screen is in scope." | Recital 25 excludes specialised computers embedded in consumer electronics. Only the Article 2(1) categories are covered. |
| "EN 301 549 clause 4 contains functional performance requirements." | Clause 4 contains functional performance statements (V3.2.1) or criteria (V4.1.1), which explain user needs; testable requirements are in clauses 5 to 13. |
| "Market surveillance runs under Regulation 765/2008." | Article 19 refers to Regulation (EC) No 765/2008, but those articles were deleted by Regulation (EU) 2019/1020 and references are read as references to it. |
Interaction with other regimes
Section titled “Interaction with other regimes”Directive (EU) 2016/2102 still governs public sector websites and apps. The general product safety regime covers safety aspects not covered by sectoral legislation. Radio products remain subject to the RED for radio, EMC and safety, with the EAA added on top; the single EU declaration of conformity then names both directives. Under Article 24(2), a feature that meets Annex I according to Section VI is presumed to meet the accessibility obligations of other Union acts for that feature, unless those acts say otherwise.
Further reading
Section titled “Further reading”- EU declaration of conformity
- Technical documentation file contents
- Market surveillance and RAPEX
- General product safety (GPSR)
- Hearing aid compatibility (HAC)
- The RED
- The CE marking
- Certification glossary
Sources and references
Section titled “Sources and references”Sources & references
- Directive (EU) 2019/882 on accessibility requirements for products and services (OJ L 151, 7.6.2019, p. 70), EUR-Lex eur-lex.europa.eu/eli/dir/2019/882/oj
- European Accessibility Act, official European Commission page, European Commission commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/european-accessibility-act-eaa_en
- EN 301 549 V4.1.1 (2026-09), accessibility requirements for ICT products and services, ETSI, CEN, CENELEC www.etsi.org/deliver/etsi_en/301500_301599/301549/04.01.01_60/en_301549v040101p.pdf
- EN 301 549 V3.2.1 (2021-03), accessibility requirements for ICT products and services, ETSI, CEN, CENELEC www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf
- Commission Implementing Decision C(2022) 6456 of September 14, 2022, standardisation request M/587 in support of Directive (EU) 2019/882 (copy hosted by CEPT), European Commission (via CEPT) cept.org/documents/wg-nan/73985/nan-2022-11-033_mandate_587_-_sr_eaa
- Implementing Decision (EU) 2021/1339, EN 301 549 V3.2.1 cited under Directive (EU) 2016/2102, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2021/1339/oj
- Web Content Accessibility Guidelines (WCAG) 2.1, W3C www.w3.org/TR/WCAG21/
- Web Content Accessibility Guidelines (WCAG) 2.2, W3C www.w3.org/TR/WCAG22/
- Regulation (EU) 2019/1020 on market surveillance, EUR-Lex eur-lex.europa.eu/eli/reg/2019/1020/oj
- Decision 768/2008/EC, common framework for the marketing of products, EUR-Lex eur-lex.europa.eu/eli/dec/2008/768/oj
- Directive (EU) 2016/2102 on public sector accessibility, EUR-Lex eur-lex.europa.eu/eli/dir/2016/2102/oj
- France, Decree No. 2023-931 of October 9, 2023 on the accessibility of products and services, Légifrance www.legifrance.gouv.fr/jorf/id/JORFTEXT000048178349
- France, Order of October 9, 2023 setting the accessibility requirements for products and services, Légifrance www.legifrance.gouv.fr/jorf/id/JORFTEXT000048178413
Frequently asked questions
- Which version of EN 301 549 do I cite in 2026?
- Two editions coexist. V3.2.1 (March 2021) follows WCAG 2.1 and is cited in the Official Journal only under the public sector Directive (EU) 2016/2102, through Implementing Decision (EU) 2021/1339. V4.1.1 (September 2026, adopted on August 24, 2026) was prepared under standardisation request C(2022) 6456 (M/587) for the European Accessibility Act: it follows WCAG 2.2 in clauses 9 to 11, revises real-time text, and adds Annex ZB and clause A.2 mapping the EAA requirements. Its own foreword says the presumption of conformity starts only once it is cited under Directive (EU) 2019/882. Until then, use V4.1.1 as the technical basis and describe your solutions requirement by requirement in the technical documentation, as Annex IV point 2(b) requires.
- When did the European Accessibility Act start to apply?
- Member States had to adopt their transposition measures by June 28, 2022 and apply them from June 28, 2025 (Article 31). The directive covers products placed on the market after June 28, 2025 (Article 2(1)). Member States may defer the 112 emergency-answering obligations of Article 4(8) to June 28, 2027 at the latest.
- Which electronic products fall under the EAA?
- The closed list is in Article 2(1): consumer general purpose computer hardware systems and their operating systems, payment terminals, ATMs, ticketing and check-in machines, interactive self-service information terminals (except those built into vehicles, aircraft, ships or rolling stock), consumer terminal equipment with interactive computing capability used for electronic communications services or for accessing audiovisual media services, and e-readers. Recital 25 excludes specialised computers embedded in consumer electronics and single components such as a mainboard; recital 30 counts a router or modem as communications terminal equipment.
- How does EN 301 549 relate to WCAG?
- EN 301 549 applies the WCAG success criteria at levels A and AA to web content (clause 9), non-web documents (clause 10) and non-web software (clause 11). V3.2.1 tracks WCAG 2.1, V4.1.1 tracks WCAG 2.2. The other clauses cover what WCAG does not: generic requirements, real-time bidirectional communication, video, hardware (including magnetic coupling to hearing technologies), product information and relay or emergency access. WCAG conformance alone does not cover a terminal or a phone.
- Does conformity with EN 301 549 give a presumption of conformity under the EAA?
- Not yet. Article 15(1) grants the presumption only to harmonised standards whose references are published in the Official Journal under Directive (EU) 2019/882, and as of October 7, 2026 we found no such publication. No technical specification has been adopted by implementing act under Article 15(3) either. Check the Official Journal again on the date you place the product on the market.
- How does a manufacturer demonstrate conformity with the EAA?
- Article 7(2) and Annex IV: internal production control by the manufacturer alone, with no notified body. The manufacturer draws up the technical documentation (general description, standards applied, and a description of the solutions adopted where no cited standard was applied), draws up the EU declaration of conformity and affixes the CE marking. Both documents are kept for five years after the product is placed on the market (Article 7(3)).
- Are microenterprises exempt?
- Only microenterprises providing services are exempt from the service requirements (Article 4(5)). A microenterprise is an enterprise with fewer than 10 persons and an annual turnover or balance sheet total not exceeding EUR 2 million (Article 3(23)). Microenterprises dealing with products must meet the product requirements; Article 14(4) only spares them from documenting a disproportionate-burden assessment, and Article 14(8) from notifying it to the authorities.
- What happens in the case of a disproportionate burden?
- Article 14 limits the requirements to what does not cause a fundamental alteration of the product or a disproportionate burden, assessed against the Annex VI criteria. The operator documents the assessment, keeps it for five years from the last making available of the product, informs the market surveillance authority of the Member State concerned (Article 14(8)) and lists the excepted requirements in the EU declaration of conformity (Article 16(1)). An operator that received funding, public or private, for improving accessibility cannot invoke disproportionate burden (Article 14(6)).
- How does it differ from Directive 2016/2102 for the public sector?
- Directive (EU) 2016/2102 covers websites and mobile applications of public sector bodies, and EN 301 549 V3.2.1 is cited under it. The EAA covers listed private-sector products and services, uses CE marking and Annex IV self-assessment for products, and as of October 7, 2026 has no cited harmonised standard. EN 301 549 V4.1.1 serves both: Annex ZA for 2016/2102 and Annex ZB for 2019/882.