The European Accessibility Act (EAA) drafters clearly didn’t want to explicitly adopt or incorporate the Web Content Accessibility Guidelines (WCAG) technical standards into the Directive. However, they did recognize the importance of the WCAG framework so they brought forward WCAG’s POUR principles.
This was an extremely smart approach. Now a technical instance of non-conformance doesn’t equate to a violation of the law. The key for EAA compliance is that your digital asset’s are perceivable, operable, understandable, and robust (POUR).
While that flexibility is helpful for covered entities, when it comes to the technical execution side, it’s much easier to audit and remediate for full WCAG 2.1 AA (or WCAG 2.2 AA) conformance. This way we ensure the general POUR requirement is met along with the technical requirements in Annex I.
Let’s analyze the different EAA excerpts where POUR is included.
We’ve bolded where “perceivable, operable, understandable, and robust” are included in the Annex.
| POUR Principle | EAA Implementation Requirements |
|---|---|
| Perceivable | Information and user interface components must be presentable through multiple sensory channels. Provide alternative text for images, captions for videos, sufficient color contrast, and audio descriptions. Content must be available to users regardless of sensory abilities. |
| Operable | All functionality must be available from a keyboard without requiring specific timings. Provide users enough time to read content, avoid seizure-inducing flashing, and ensure navigation is consistent. Users must be able to operate interface components regardless of physical abilities. |
| Understandable | Text must be readable and understandable, with consistent navigation patterns. Provide clear error identification and correction instructions. Content and interface operation must be predictable for users with cognitive disabilities. |
| Robust | Content must work reliably across different user agents and assistive technologies. Use valid, semantic markup that can be interpreted by current and future assistive technologies including screen readers and voice control software. |
Table of Contents
Recitals: WCAG’s POUR Principles Are Relevant
The European Accessibility Act doesn’t leave you guessing about its accessibility framework. Right in recital (47), the Act makes an explicit declaration:
“The four principles of accessibility of websites and mobile applications, as used in Directive (EU) 2016/2102, are: perceivability, meaning that information and user interface components must be presentable to users in ways they can perceive; operability, meaning that user interface components and navigation must be operable; understandability, meaning that information and the operation of the user interface must be understandable; and robustness, meaning that content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies. Those principles are also relevant for this Directive.”
This foundational statement establishes that the EAA intentionally adopts the same four principles (Perceivable, Operable, Understandable, Robust) that form the backbone of WCAG 2.1. This isn’t coincidental—it’s deliberate legal alignment.
How the POUR Principles Flow Through the EAA’s Technical Requirements
Following the chronological structure of the Act’s technical requirements, we can see how these POUR principles are systematically applied:
Section III: General Service Requirements – The First Major Application
Section III of Annex I establishes general accessibility requirements for all services. Here’s where we first see the POUR principles applied in the technical requirements:
Point (b)(vii) – Electronic Information Requirements
“providing electronic information needed in the provision of the service in a consistent and adequate way by making it perceivable, operable, understandable and robust“
This requirement applies to all electronic information provided as part of any service covered by the EAA.
Point (c) – Website and Mobile App Requirements
“making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust“
This sweeping requirement covers all digital interfaces for services, explicitly requiring the complete POUR framework.
Section IV: Specific Service Requirements – Detailed Applications
Moving chronologically through Section IV of Annex I, we see the POUR principles applied to specific service types:
Point (b) – Audiovisual Media Services
“providing electronic programme guides (EPGs) which are perceivable, operable, understandable and robust and provide information about the availability of accessibility”
Electronic program guides must meet all four POUR principles.
Point (e) – Consumer Banking Services
“providing identification methods, electronic signatures, security, and payment services which are perceivable, operable, understandable and robust“
All banking interface elements must comply with the complete POUR framework.
Point (f) – E-books
“allowing alternative renditions of the content and its interoperability with a variety of assistive technologies, in such a way that it is perceivable, understandable, operable and robust“
Note how the EAA lists the principles in a slightly different order here, but requires all four.
Point (g) – E-Commerce Services (Two Separate Requirements)
Point (g)(ii):
“ensuring the accessibility of the functionality for identification, security and payment when delivered as part of a service instead of a product by making it perceivable, operable, understandable and robust“
Point (g)(iii):
“providing identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust“
E-commerce services have dual requirements, both explicitly requiring all four POUR principles.
Supporting Requirements That Reinforce POUR Principles
Between these explicit POUR principle citations, the EAA includes detailed supporting requirements that align with WCAG’s approach:
Section III(b) requires information to be:
- “available via more than one sensory channel” (supporting Perceivable)
- “presented in an understandable way” (supporting Understandable)
- “presented to users in ways they can perceive” (supporting Perceivable)
- Available “in text formats that can be used to generate alternative assistive formats” (supporting Robust)
- Provided “with an alternative presentation” for non-textual content (supporting Perceivable)
These detailed requirements provide the same type of specific guidance found in WCAG 2.1 AA success criteria.
WCAG 2.1 AA Standard
1. Explicit Legal Recognition
The chronological flow from recital (47) through the technical requirements shows deliberate adoption of WCAG’s framework. The EAA doesn’t just happen to use similar language—it explicitly states that WCAG’s principles “are also relevant for this Directive.”
2. Comprehensive Coverage
Following the chronological order, we see that the EAA applies the POUR principles to:
- All electronic information (Section III(b)(vii))
- All websites and mobile applications (Section III(c))
- Electronic program guides (Section IV(b))
- Banking services (Section IV(e))
- E-book platforms (Section IV(f))
- E-commerce platforms (Section IV(g) – twice)
This comprehensive application means that WCAG 2.1 AA compliance addresses the core requirements across all major service categories.
3. Harmonized Standards Provide Legal Certainty
Article 15 of the EAA establishes that conformity with harmonized standards creates presumption of compliance:
“Products and services which are in conformity with harmonised standards or parts thereof the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the accessibility requirements of this Directive”
EN 301 549, which incorporates WCAG 2.1 AA will very likely be the harmonized standard at some point in 2025 or 2026. However, at that time, we may see WCAG 2.2 AA incorporated. Nevertheless, EN 301 549 still serves as an extremely helpful reference and is currently connected to WCAG 2.1 AA.
4. One Standard, Multiple Benefits
By following WCAG 2.1 AA, you simultaneously address:
- The foundational principles established in recital (47)
- The general service requirements in Section III
- The specific service requirements in Section IV
- Compliance with EN 301 549
- International accessibility best practices
The Practical Path Forward
The chronological flow through the EAA shows a clear legal architecture: foundational principles in the recitals, general application in Section III, and specific implementation in Section IV. All point toward the same conclusion.
Rather than trying to interpret each detailed requirement separately, recognize that:
- Recital (47) gives you legal permission to use WCAG’s framework
- Section III applies this framework broadly to all services
- Section IV applies it specifically to individual service types
- Article 15 provides legal certainty through harmonized standards
Conclusion
The European Accessibility Act’s structure for digital accessibility technical requirements is built upon WCAG’s foundational principles through general requirements to specific applications. The Directive doesn’t just reference WCAG’s POUR principles once; it systematically applies them throughout its technical requirements.
We recommend clients work towards either WCAG 2.1 AA conformance or WCAG 2.2 AA.
If you’d like help with EAA compliance, contact us and we’ll be right with you.
