Directive (EU) 2016/2102, the EU Web Accessibility Directive, has applied in full to public sector websites and mobile apps across the EU since June 2021. Its deadlines have passed. What remains is ongoing compliance: accessibility statements, national monitoring every three years, and a technical standard that changed in September 2026.
This FAQ covers what the directive requires of public sector bodies now. For a shorter definition and a comparison with the European Accessibility Act, see Siteimprove's EU Web Accessibility Directive glossary entry.
EU Web Accessibility Directive FAQs
What is Directive (EU) 2016/2102?
Directive (EU) 2016/2102 sets minimum accessibility requirements for the websites and mobile apps of public sector bodies in the EU. It was adopted on 26 October 2016 and entered into force on 22 December 2016. As a directive, it takes effect through national law, which member states had to adopt by 23 September 2018.
The core requirement is in Article 4: websites and apps must be perceivable, operable, understandable and robust, the four principles of accessibility that WCAG is built on.
Who does the directive apply to?
Public sector bodies, which Article 3 defines as state, regional and local authorities, bodies governed by public law, and associations formed by them. In practice that covers ministries, municipalities, police services, public libraries, public hospitals and public universities.
The obligation sits with the public body, not its suppliers. Public bodies pass it on through procurement, so vendors that build their websites or apps are usually bound by contract to the same standard.
The directive is a minimum. Under Article 2, member states can go further, so check your national law.
Does the directive apply to private businesses?
Not directly. Private sector accessibility is covered by the European Accessibility Act, Directive (EU) 2019/882, adopted on 17 April 2019. Its requirements have applied to a defined set of products and services since 28 June 2025. Our European Accessibility Act FAQ covers its scope.
Who and what is exempt?
Article 1(3) puts two kinds of website and app outside the directive: those of public service broadcasters, and those of NGOs that provide neither services essential to the public nor services specifically for persons with disabilities. Under Article 1(5), member states may also exclude schools, kindergartens and nurseries, except for content relating to essential online administrative functions.
Article 1(4) excludes certain content, mostly by date:
| Content | Excluded when |
|---|---|
| Office file formats (PDF, Word and similar) | Published before 23 September 2018, unless needed for active administrative processes |
| Pre-recorded audio and video | Published before 23 September 2020 |
| Live audio and video | Always |
| Online maps | Essential information is provided in an accessible digital form for maps used for navigation |
| Third-party content | Neither funded, developed nor controlled by the public body |
| Reproductions of heritage collections | They cannot be made fully accessible without compromising preservation or authenticity, or no cost-efficient way to do so exists |
| Intranets and extranets | Published before 23 September 2019, until substantially revised |
| Archives | Not needed for active administrative processes and not updated after 23 September 2019 |
PDFs, video and audio published after those dates are in scope.
What is disproportionate burden?
Under Article 5 of the directive, a public body may limit accessibility where meeting a requirement would impose a disproportionate burden. The body assesses this itself, weighing its size and resources against the costs and the benefits to persons with disabilities. There is no application to a regulator. The body must explain in its accessibility statement which requirements it could not meet, and offer accessible alternatives.
When did the requirements apply?
| Content | Requirements applied from |
|---|---|
| Websites published on or after 23 September 2018 | 23 September 2019 |
| Websites published before 23 September 2018 | 23 September 2020 |
| Mobile apps | 23 June 2021 |
All three dates have passed, so every public sector website and app in scope is expected to meet the requirements now.
Do we need an accessibility statement?
Yes. Article 7 requires every public sector body, at national, regional and local level, to publish a detailed, comprehensive and clear accessibility statement for each website and app, and to keep it updated. The Commission's model statement, set out in Implementing Decision (EU) 2018/1523, defines what it must contain: which content is not accessible and why, any disproportionate burden claimed, accessible alternatives, a feedback mechanism and a link to the enforcement procedure. Siteimprove's guide covers how to write an accessibility statement.
How should user feedback work?
The feedback mechanism in the statement lets anyone report content that is not accessible or request information in an accessible form, and the public body must respond adequately within a reasonable time. The Commission's review found that public bodies knew about the mechanism but end users rarely did. Make it easy to find, and route reports to someone who owns the fix.
Will our websites be monitored?
Yes. Article 8 requires member states to monitor public sector websites and apps periodically, using the Commission's methodology in Implementing Decision (EU) 2018/1524. It combines simplified monitoring of a larger sample with in-depth monitoring of a smaller one. Member states report the results every three years. The first reports were due in December 2021, the second in December 2024, and the next are due in December 2027. The Commission publishes each member state's monitoring reports.
Who is responsible for compliance?
Three roles are involved. The public body is responsible for its own websites and apps, its accessibility statement and its response to feedback. A national monitoring body checks samples and reports to the Commission. An enforcement body, required by Article 9, handles cases where a user is not satisfied with the public body's response. Your country's monitoring report names the bodies that apply to you.
Can we be fined?
The directive does not set fines. Penalties, where they exist, are set in national law, so check your country's transposing legislation.
Does the directive apply outside the EU?
The directive is relevant to the European Economic Area, so Norway, Iceland and Liechtenstein implement it through the EEA Agreement on their own timelines. Countries outside the EEA are not bound by it. Check national law for the current position.
What challenges have organizations faced?
The Commission's review of the directive's first three years (SWD(2022) 411) found that the legal machinery is in place but much practical work remains. Its findings for public bodies:
- A shortage of accessibility expertise in both the public and private sectors makes it hard to procure accessible solutions or recruit specialists.
- Most content falls into the "partially compliant" category, and there is no common definition of non-, partially and fully compliant, so monitoring results are hard to compare across countries.
- Most work to date has targeted visual impairment, while requirements for cognitive impairment are still being developed.
- Public bodies that embed accessibility in their digital strategies do better than those that treat it as a one-off project.
Standards FAQs
How do the directive, EN 301 549 and WCAG relate?
| Instrument | What it is | What it does |
|---|---|---|
| Directive (EU) 2016/2102 | EU law, applied through national law | Sets scope, obligations, the accessibility statement, monitoring and enforcement |
| EN 301 549 | Harmonised European standard from ETSI, CEN and CENELEC | Sets the technical requirements; under Article 6, conformance gives a presumption of conformity with the directive |
| WCAG | Technical standard from the W3C | Supplies the success criteria EN 301 549 uses for web content; it is not law on its own |
EN 301 549 is broader than WCAG. It also covers documents, software and mobile apps, so conforming to WCAG covers most but not all of what the standard requires of a public sector website or app.
Is WCAG 2.1 or 2.2 required?
Today, the reference standard for the directive is EN 301 549 V3.2.1, cited through Implementing Decision (EU) 2021/1339, and it uses WCAG 2.1 Level AA for web content.
That is changing. EN 301 549 V4.1.1, published on 2 September 2026, moves the web content baseline to WCAG 2.2 Level AA and updates its mapping to the directive. It gives a presumption of conformity only once its reference is published in the Official Journal of the EU. Until then, V3.2.1 remains the reference, and some national laws name a specific version, so check yours. In practice: add the new WCAG 2.2 criteria to your testing, write them into procurement specifications for new builds, and plan to update accessibility statements when your national law moves to the new version.
What do WCAG Levels A, AA and AAA mean?
They are conformance levels. Each WCAG success criterion is assigned Level A (the minimum), AA or AAA (the highest). Conforming at Level AA means meeting every Level A and Level AA criterion. Under the directive, the target is set by EN 301 549, which means Level AA. It is not a level you choose.
To browse the success criteria by level, use the Quick Reference to WCAG 2.1 requirements and techniques provided by the W3C.
What changed between WCAG 2.0, 2.1 and 2.2?
WCAG 2.1, published in 2018, kept all of WCAG 2.0 and added criteria for mobile use, low vision, and cognitive and learning disabilities, for 78 success criteria in total. WCAG 2.2, published in October 2023, adds nine criteria, covering areas such as focus visibility, dragging, target size and accessible authentication, and removes 4.1.1 Parsing.
Testing and compliance FAQs
How do we find out if our websites comply?
Combine automated monitoring across every website and app you are responsible for, manual review against EN 301 549 and WCAG, and testing with people with disabilities. That mirrors national monitoring, which pairs largely automated simplified checks with in-depth reviews.
Why isn't automated testing enough?
Automated checks find only part of the issues WCAG covers. Many success criteria need human judgment, such as whether alt text is meaningful, whether reading order makes sense, or whether a process works by keyboard from start to finish. A mix of automated and manual testing gives the most reliable results for the time and resources spent. See why manual testing belongs in your accessibility strategy, and use Web accessibility quick fixes: A content creator's checklist for what to check.
What does ongoing compliance look like?
The directive's deadlines have passed, but compliance is a continuing process. A working program includes:
- Build an accessibility team of people responsible for accessibility in your organization
- Raise awareness about accessibility and understand the issues faced by people with disabilities
- Get an overview of all the websites, domains, and apps your organization is responsible for
- Audit your websites, domains, and apps to evaluate the extent of the issues with accessibility
- User testing with people with disabilities or barriers
- Prepare a detailed accessibility plan, with tasks organized by priority, difficulty and owner, and review cycles that line up with your national monitoring
- Prepare training material
- Publish your accessibility statement and keep it current
- Act on feedback from users
- Monitor continuously and report results
For further guidance, the Web Accessibility Directive FAQ maintained by the WAI-CooP project answers detailed implementation questions, and the W3C's WCAG overview explains the guidelines. Siteimprove's web accessibility guides and checklists go deeper on individual topics.
