Standard
EN 301 549 clause 10: accessibility requirements for non-web documents
The European harmonised standard for ICT procurement. Clause 10 is the one that governs PDFs, and it points squarely at WCAG 2.1 Level AA.
ETSI, CEN and CENELEC · technical standard: WCAG 2.1 Level AA (clause 9), applied to documents through clause 10
What clause 10 asks of a document
Clause 10 is the shortest route from a procurement requirement to a concrete list of things to check, because it is WCAG restated for documents. In practice that means:
Structure that reflects meaning. Headings tagged as headings, lists as lists, tables with real header associations. Clause 10.1.3.1, mapping to WCAG 1.3.1.
A reading order that matches intent. Clause 10.1.3.2, mapping to WCAG 1.3.2. In a PDF this is the structure tree, and it is where most of the work is. Why tags read out of sequence →
Text alternatives. Clause 10.1.1.1: every image either carries a description or is declared decorative.
A determinable language. Clauses 10.3.1.1 and 10.3.1.2. Critical in multilingual EU documents, where per-passage language is the norm rather than the exception. How →
Accessible form controls. Clause 10.4.1.2: a name, a role and a value for every field. In PDF that means /TU. How →
Procurement is where this shows up
Most people meet EN 301 549 through a tender clause rather than a statute. That has two practical consequences.
First, the requirement usually arrives with a deadline attached to a delivery date rather than a regulatory one, which means less notice.
Second, the buyer will often ask for evidence rather than an assertion. A remediation report showing what was checked, what was fixed, what was accepted and by whom is a far stronger answer than a claim of conformance.
Taggart’s report is designed for exactly that handover: findings mapped to both PDF/UA-1 clauses and WCAG success criteria, a timestamped decision log, the tool version, and the SHA-256 of the source and output files.
Frequently asked questions
What is clause 10 and why does it matter for PDFs?
Clause 9 applies WCAG to web content. Clause 10 applies the same success criteria to non-web documents, with wording adjusted where a criterion refers to web concepts. A PDF attached to an email or downloaded from a portal is a non-web document, so clause 10 is the one that governs it.
Does EN 301 549 add anything WCAG does not?
For documents, very little at Level AA — clause 10 is essentially WCAG restated for the non-web case. The additions in EN 301 549 are mostly in the hardware, software and support-service clauses. If you meet WCAG 2.1 AA for a document, clause 10 is largely satisfied.
Is it mandatory?
It is the harmonised standard for public procurement of ICT in the EU under Directive 2016/2102, so it typically arrives through a contract rather than directly. If a tender asks for EN 301 549 conformance, the documents you deliver are in scope.
How does this relate to the European Accessibility Act?
EN 301 549 is the technical standard; the EAA is the legal instrument extending accessibility duties to private-sector products and services. Conformance with the standard is how an organisation demonstrates it has met the Act's requirements for covered ICT.
Related failure conditions
- 09-001 Tags are not in logical reading order The order of elements in the structure tree does not match the order a human would read the page. This is the single most common substantive defect in tagged PDFs and the one Acrobat's own tooling handles worst.
- 11-001 Natural language for text in page content cannot be determined No /Lang is in effect for some text: neither on the catalog, nor on an enclosing structure element, nor on a marked-content sequence.
- 13-004 Figure tag alternative or replacement text missing A Figure element has neither /Alt nor /ActualText. Every Figure must have one or the other; if the image is decorative it should be an artifact instead of a Figure.
- 14-003 Numbered heading levels in descending sequence are skipped The heading hierarchy jumps a level going down — H1 straight to H3. Going back up any number of levels is fine; going down must be one level at a time.
- 28-005 A form field has neither a TU entry nor an alternative description The /TU tooltip is the accessible name of a PDF form field. Without it the field has no name at all — the visible label printed next to it is not connected to the control.
Check your own file. Taggart's validator is free and unlimited — no page cap, no watermark, no account.
Primary source: https://www.etsi.org/deliver/etsi_en/301500_301599/301549/. This page is a working summary, not legal advice.
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