When I first prepared for WCAG certification and later specialised in RGAA for projects in France, I thought these two standards would be enough to cover accessibility work both locally and internationally.
But the European landscape is more complex. Beyond WCAG as the technical foundation, there’s EN 301 549, which makes accessibility legally enforceable across the EU. Several countries also add national standards like RGAA (France), BITV (Germany), UNE 139803 (Spain) or Italy’s Legge Stanca, each with their own tests and clarifications. In Scandinavia, WCAG applies directly, supported by national agencies like Sweden’s DIGG.
With the European Accessibility Act now in force since June 28 2025, these differences matter more than ever, shaping audits, statements and design decisions for both public and private sectors.
In this article I tried to offer a clear comparison: when each standard appeared, where it applies, how strict it is, and what it adds to WCAG — to help teams see the bigger picture of accessibility across Europe.
1. WCAG – Web Content Accessibility Guidelines
| Aspect | Details |
| Published by | W3C (World Wide Web Consortium) |
| First version | WCAG 1.0 in 1999; WCAG 2.0 in 2008; WCAG 2.1 in 2018; WCAG 2.2 in October 2023; WCAG 3 (draft, not final) |
| Where it applies | International — referenced worldwide (EU, US, UK, Canada, Australia, etc.) |
| Legal status | Not legally binding by itself — becomes mandatory when referenced in law (e.g., EU Directive, ADA settlements, UK regulations) |
| How strict? | Provides guidelines organised under POUR (Perceivable, Operable, Understandable, Robust); testable “success criteria” at levels A, AA, AAA |
| Checking | By running accessibility audits / manual testing / automated tools against the success criteria (e.g., contrast ratio, focus indicators, alt text) |
| Key point | WCAG itself doesn’t tell you how to document or publish; it’s purely technical. It’s the backbone everyone builds on. |
| Practicality & detail level | Abstract & principle‑based: explains what must be done, but not how to do it. Good for high‑level guidance. |
| Best suited for | Designers (color contrast, focus order, content clarity) Front‑end devs (semantic HTML, ARIA, keyboard nav) Product managers & content teams (clear language, consistent structure) |
2. EN 301 549 – European standard
| Aspect | Details |
| Published by | CEN/CENELEC & ETSI (European standardisation bodies) |
| First version | 2014 (EN 301 549 v1.0); updated regularly — current version EN 301 549 v3.2.1 (2021), aligned with WCAG 2.1; WCAG 2.2 update expected |
| Where it applies | All EU member states, as well as EEA countries (e.g., Norway, Iceland); cited in EU laws like the Web Accessibility Directive (2016/2102) and the European Accessibility Act (2019/882) |
| Legal status | Legally binding once referenced in an EU Directive or Regulation; becomes the technical means to prove compliance (“presumption of conformity”) |
| How strict? | Requires public sector websites/apps to meet WCAG success criteria (currently 2.1 AA); also adds requirements for documents, video, software, authoring tools, hardware, biometrics |
| Checking | By technical audits + mandatory accessibility statement (EU template); may require documentation & conformity assessments, especially under the EAA |
| Key point | EN 301 549 is what turns WCAG from a voluntary guideline into a concrete legal obligation in Europe. |
| Practicality & detail level | Formal legal text + references to WCAG; adds requirements for documents, video players, software & hardware. Not a daily reference for coding; useful for compliance leads, legal & procurement. |
| Best suited for | Compliance officers & DPOs Accessibility leads Project managers (to check scope: documents, software, apps) |
3. RGAA – Référentiel Général d’Amélioration de l’Accessibilité (France)
| Aspect | Details |
| Published by | French government (DINUM – Direction interministérielle du numérique) |
| First version | 2009; current: RGAA 4.1 (2023), aligned with WCAG 2.1; update to WCAG 2.2 expected soon |
| Where it applies | France — all public websites, mobile apps, intranets, extranets; many private companies offering digital services to the public (especially >250 employees) |
| Legal status | Mandatory by French law (Law n°2005‑102 on equal rights for disabled people; decrees from 2009, updated 2019) |
| How strict? | Adds detailed test procedures (approx. 106 criteria) that say how to check each WCAG point; requires: an accessibility statement in French, updated annually; publication of an “audit report” summarising findings; “multi‑year plan” for improvement |
| Checking | Through an RGAA audit (can be internal or by a certified expert); audit follows official test procedures; must publish the results |
| Key point | RGAA is not just a copy of WCAG — it’s a practical, test‑oriented standard + legal obligation + strong transparency requirements. |
| Practicality & detail level | Highly practical: step‑by‑step test criteria, concrete examples, yes/no checks. Makes WCAG actionable. |
| Best suited for | Front‑end developers & integrators (checklists before release) QA testers / auditors (run the tests) Some points help designers (e.g., contrast, structure) |
4. BITV 2.0 – Germany
| Aspect | Details |
| Published by | Federal Ministry of Labour and Social Affairs |
| Since | BITV 1.0 in 2002 (aligned with WCAG 1.0); BITV 2.0 from 2011, updated in 2019 & 2021 to align with WCAG 2.1 |
| Where it applies | All German federal and state public bodies; since EAA, also certain private sectors |
| Legal status | Mandatory by German law: Barrierefreie-Informationstechnik-Verordnung (Ordinance on Accessible Information Technology), based on Behindertengleichstellungsgesetz (BGG, Equal Opportunities for Disabled Persons Act) |
| Adds to WCAG | Has detailed testing procedure (BITV-Test) developed by DIAS & BIK project; adds clarifications in German, practical examples, recommended methods to test consistency across audits |
| Practicality | Quite practical: BITV-Test is structured into checkpoints; easy for testers & devs to follow; less abstract than pure WCAG |
| Best suited for | Auditors & QA teams (use BITV-Test) Front‑end devs & integrators (follow checkpoints during implementation) Designers (get clarity on contrast & structure) Legal & compliance teams (less detailed legal text; main law is BGG & BITV text) |
| Aspect | Details |
| Published by | AENOR (Spanish Association for Standardisation) |
| Since | First version 2004 (based on WCAG 1.0); current UNE 139803:2012 aligned with WCAG 2.0 |
| Where it applies | Spanish public sector; private companies in certain regulated sectors; recommended for private companies to self‑declare |
| Legal status | Not directly a law, but referenced by Spanish legislation (Ley 34/2002 and Ley 51/2003) & Royal Decree 1112/2018 (implements EU Directive) |
| Adds to WCAG | Offers clarifications, national context & practical guidance for Spanish content (e.g., Spanish‑specific language issues, legal texts) |
| Practicality | Practical for audits and self‑declarations: gives detailed criteria, structured in “priority levels” similar to WCAG AA |
| Best suited for… | Auditors & consultants (use UNE as checklist) Front‑end devs (follow concrete criteria) Designers (color, language, forms) Legal/compliance (main law is Royal Decree, UNE supports the technical implementation) |
6. Legge Stanca & Decreto Ministeriale – Italy
| Aspect | Details |
|---|---|
| Published by | Italian Parliament (Law 4/2004, known as Legge Stanca); updated by Ministry Decree. |
| First version | Legge Stanca in 2004 (based on WCAG 1.0); updated 2013 to align with WCAG 2.0; further aligned after EU Directive. |
| Where it applies | Public sector, some private bodies providing public services or receiving public funds. |
| Legal status | National law — non‑compliance can lead to penalties, exclusion from tenders. |
| How strict? | WCAG 2.0 AA level + Allegato A (Annex A): practical checklist that says what must be checked (like RGAA, but shorter). |
| Checking | Self‑assessment & audits using Allegato A; national monitoring. |
| Key point | Adds national clarifications & test points, especially for Italian content, forms, language. |
| Practicality & detail level | More practical than raw WCAG: Allegato A is concrete, though less detailed than RGAA. |
| Best suited for | Auditors & QA teams (use Allegato A) Front‑end devs (specific test points) Designers (structure, color, clarity) Backend engineers: only if backend affects output |
While each standard has its own history, scope and national context, they all share a common goal: turning WCAG’s technical principles into concrete, enforceable and testable requirements adapted to local legal systems and practical needs.
Taken together, they form a layered framework:
- WCAG as the international backbone;
- EN 301 549 making those requirements legally binding across the EU and EEA;
- and national standards like RGAA, BITV, UNE 139803 and Legge Stanca adding country‑specific tests and clarifications.
To make these differences easier to see at a glance, here’s a comparison table summarising when each standard appeared, where it applies, its legal status, what it adds on top of WCAG, and how compliance is usually checked.
| Standard | Since | Where | Legal? | Adds to WCAG | How to check |
|---|---|---|---|---|---|
| WCAG | 1999+ | Worldwide | Voluntary unless in law | Technical guidelines only | Audits vs success criteria |
| EN 301 549 | 2014+ | EU & EEA | Yes, by EU law | Covers more than websites (apps, docs, hardware) | Audit + accessibility statement |
| RGAA | 2009+ | France | Yes | Detailed tests & audit process | Official audit + yearly update |
| BITV | 2002+ | Germany | Yes | Adapted test procedure for audits | Manual audit + declaration |
| UNE 139803 | 2004+ | Spain | Yes | Spanish clarifications & checklist | Audit or self-assessment |
| Legge Stanca | 2004+ | Italy | Yes | Concrete test points added | Self-assessment + audit |
In summary, while WCAG forms the foundation of web accessibility, understanding regional standards like EN 301 549, RGAA, BITV, UNE 139803, and Legge Stanca is essential for effective compliance across Europe. Each standard reflects local legal requirements and practical approaches, making it important to align accessibility efforts with the specific regulations of the target market.
Leave a Reply