1. Overview
Clause 11, "Non-web software", covers everything that runs as a program rather than a page. That includes operating systems, desktop applications, kiosk software and native mobile apps. The clause has two halves.
Clauses 11.1 to 11.4 mirror the WCAG 2.2 success criteria. The standard adjusts the wording where a web concept has no equivalent in software. It leaves a few requirements void.
Clause 11.5 sets out how software must expose itself to assistive technology. It does this through the platform's accessibility services, element by element. So a screen reader can learn the role, name, state and value of every control. It can also act on each control. Clauses 11.6 and 11.7 cover the platform's own accessibility features and the user's preference settings.
This lesson explains four things. First, who clause 11 applies to. Second, where the software wording differs from WCAG. Third, what each of the thirteen 11.5.2 requirements asks for. Fourth, how the clause maps to the European Accessibility Act (EAA). The exercise at the end is a VoiceOver walkthrough of your own app, recorded against 11.5.2.
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Sources
- ETSI, CEN and CENELEC, EN 301 549 V4.1.1 (2026-09), clauses 1, 5.1, 5.2, 5.10, 11.0 to 11.7 and 14.3, Table A.3, Annex C (C.11.5.2.5) and Annex ZB Tables ZB.2 and ZB.4, available from the ETSI standards server.
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2 and the Group Note Guidance on Applying WCAG 2 to Non-Web Information and Communications Technologies (WCAG2ICT), which clause 11 follows.
- Directive (EU) 2019/882 (the European Accessibility Act), Annex I, Section I point 2 and Section III(c).
- Apple, Turn on and practise VoiceOver on iPhone, for the gestures used in the walkthrough.