EN 301 549 is the European standard that turns WCAG and related requirements into a procurement and compliance specification, and it is the only major standard with a clause written specifically for documents that are not web pages. Because it underpins the EU Web Accessibility Directive, the European Accessibility Act's technical work, the UK's regulations, and Canada's national standard, understanding clause 10 is the fastest way to understand what "accessible document" means across all of them. This guide reads clause 10 from the standard's text and sets out the version and legal-status questions that cause the most confusion.
What clause 10 covers
Clause 10.0 states that the requirements in clause 10 apply to "documents that are not web pages; documents that are not embedded in web pages; and documents that are provided with web pages but are neither embedded nor rendered together with the web page from which they are provided (i.e. the present clause applies to downloadable documents)". Documents in or embedded in web pages, rendered together with the page, are covered by clause 9. The clause's notes give examples ("letters, spreadsheets, emails, books, pictures, presentations, and movies that have an associated user agent"), record that a document may consist of several files, and point to clause 11 for the requirements on the software that displays a document. Note 7 is the one records teams should read twice: requirements in clause 10 "also apply to documents that are protected using mechanisms such as digital signatures, encryption, password protection, and watermarks when they are presented to the user". Note 5 records that the clause is intended to harmonise with the W3C's WCAG2ICT guidance.
The requirements
Clause 10 is organised on WCAG's four principles and its numbering tracks the WCAG success criteria one for one, so 10.1.1.1 is Non-text content, 10.1.3.1 is Info and relationships, 10.2.4.2 is Document titled, and 10.4.1.3 is Status messages. Where a WCAG criterion does not apply to a document the standard inserts a "void" clause to keep the numbering aligned with clauses 9 and 11. The table below lists the requirements that matter most for PDFs and Office documents; the full clause runs from 10.1.1.1 to 10.4.1.3 and adds 10.5 (caption positioning) and 10.6 (audio description timing) for documents with media.
| Clause | Requirement | In a document this means |
|---|---|---|
| 10.1.1.1 | Non-text content | Alternative text for meaningful images; decorative images hidden |
| 10.1.3.1 | Info and relationships | Headings, lists, and table headers exposed as structure (tags) |
| 10.1.3.2 | Meaningful sequence | A reading order that matches the intended order |
| 10.1.3.3 | Sensory characteristics | Instructions not dependent on shape, colour, or position alone |
| 10.1.4.1 | Use of colour | Colour is not the only carrier of meaning |
| 10.1.4.3 | Contrast (minimum) | Text contrast of at least 4.5:1 (3:1 for large text) |
| 10.1.4.5 | Images of text | Real text rather than pictures of text |
| 10.1.4.10 | Reflow | Content can be presented without two-dimensional scrolling at 320 CSS pixels width |
| 10.2.1.1 | Keyboard | Form fields and links usable from the keyboard |
| 10.2.4.2 | Document titled | A descriptive title that assistive technology can read |
| 10.2.4.3 | Focus order | Tab order that follows the structure |
| 10.2.4.4 | Link purpose (in context) | Link text that says where it goes |
| 10.2.4.6 | Headings and labels | Headings and form labels that describe their content |
| 10.3.1.1 | Language of document | The document language declared |
| 10.3.1.2 | Language of parts | Passages in other languages marked |
| 10.3.3.1 to 10.3.3.4 | Input assistance | Error identification, labels and instructions, error suggestions, and error prevention in forms |
| 10.4.1.2 | Name, role, value | Form fields expose an accessible name, role, and value |
Two entries deserve comment. Reflow (10.1.4.10) is a WCAG 2.1 criterion that a fixed-layout PDF cannot meet in the way a web page does; the standard applies it to documents and leaves the document's viewer to supply reflow where the format allows, which is one of the strongest arguments in the standard for publishing HTML alongside PDF. Document titled (10.2.4.2) and the language clauses map directly to the document-level settings in the settings guide. The mapping from WCAG to PDF techniques in the WCAG 2.2 AA document guide applies to clause 10 as well.
Versions and legal status
V3.2.1 (2021-03) is the current published version and the one that carries legal weight. Commission Implementing Decision (EU) 2021/1339 of 11 August 2021 cited EN 301 549 V3.2.1 in the Official Journal as the harmonised standard for websites and mobile applications under the Web Accessibility Directive (2016/2102), which is how it became the yardstick for public sector documents across the EU. Clauses 9, 10, and 11 of V3.2.1 correspond to WCAG 2.1 Level A and AA.
V4.1.0 (final draft, 2026-06) is on ETSI's delivery server as a final draft harmonised European standard, dated June 2026. It is the revision expected to move clauses 9, 10, and 11 to WCAG 2.2. A draft has no legal effect: a European standard confers a presumption of conformity with a Directive only once the Commission cites it in the Official Journal, and until that happens for a new version, V3.2.1 remains the cited version for the Web Accessibility Directive. Check the Official Journal, not the ETSI server, for the version that applies.
How the European Accessibility Act uses it
Directive (EU) 2019/882, the European Accessibility Act, applies to a list of products placed on the market and services provided to consumers after June 28, 2025: among others, e-readers; consumer banking services; e-books and dedicated software; and e-commerce services (Article 2). Its accessibility requirements are functional and are set out in Annex I rather than by reference to WCAG or EN 301 549; Article 4(5) exempts microenterprises providing services, and Article 32 provides a transitional period to June 28, 2030 for services using products lawfully in use before the date and for service contracts agreed before June 28, 2025. Article 2(4) excludes from the Act's website and app content requirements office file formats published before June 28, 2025, online maps where essential information is provided accessibly, third-party content not under the operator's control, and archived content not updated after that date.
EN 301 549 is the standard the Commission has asked the European standards organisations to revise so that it can serve as a harmonised standard under the Act. Once a version is cited in the Official Journal for the EAA, products and services conforming to it will be presumed to conform to the corresponding Annex I requirements. Until then, an organisation in scope of the EAA should treat clause 10 as the best available specification of what an accessible document is, and Annex I as the legal test. For e-books specifically, the W3C has published a mapping of the Annex I requirements to EPUB; see the EAA and e-books.
Beyond the EU
Two other regimes adopt the same standard. The UK's public sector regulations derive from the same Directive, and GOV.UK now names WCAG 2.2 AA directly; see UK public sector PDFs. Canada adopted EN 301 549 V3.2.1 as the national standard CAN/ASC-EN 301 549:2024, and the December 2025 amendments to the Accessible Canada Regulations require federally regulated entities' web pages, mobile apps, and non-web documents to conform to it; see Canada's requirements.
Frequently asked questions
What does EN 301 549 clause 10 apply to?
Clause 10 applies to documents that are not web pages, are not embedded in web pages, or are provided with web pages as downloads, which covers PDFs, Office files, e-books, and similar files that need a document reader. Documents embedded in a page and rendered with it fall under clause 9. The standard's notes add that the requirements also apply to documents protected by signatures, encryption, passwords, or watermarks.
Which version of EN 301 549 is legally in force?
EN 301 549 V3.2.1, published in March 2021, is the version cited in the Official Journal of the European Union by Commission Implementing Decision (EU) 2021/1339 for the Web Accessibility Directive, and its clauses 9, 10, and 11 correspond to WCAG 2.1 Level A and AA. A final draft V4.1.0 dated June 2026, expected to move to WCAG 2.2, has been published by ETSI but has no legal effect until it is cited in the Official Journal.
Does the European Accessibility Act require WCAG or EN 301 549 for documents?
The Act's requirements are functional and are set out in Annex I; it does not itself name WCAG or EN 301 549. It has applied since June 28, 2025 to listed products and services including e-books, consumer banking, and e-commerce, and excludes office file formats published before that date from its website content requirements. EN 301 549 is being revised to serve as a harmonised standard under the Act, which would give conforming documents a presumption of conformity once the version is cited in the Official Journal.
Sources
The statements above rest on the primary sources below. Where a source is a law or standard, the version and date named in the text are the ones checked on the review date. This guide is general information, not legal advice.
- ETSI: EN 301 549 V3.2.1 (2021-03), Accessibility requirements for ICT products and services (PDF) . Clause 10.0 scope and notes, and the clause 10 requirement list, quoted above.
- ETSI: Final draft EN 301 549 V4.1.0 (2026-06) (PDF)
- EUR-Lex: Commission Implementing Decision (EU) 2021/1339 of 11 August 2021 . Citation of EN 301 549 V3.2.1 as the harmonised standard under Directive (EU) 2016/2102.
- EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act) . Articles 2, 4, 31, and 32 and Annex I, as quoted.
- W3C: EPUB Accessibility, EU Accessibility Act Mapping (Group Note, August 28, 2025)
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