1. Overview
EN 301 549 is the European standard "Accessibility requirements for ICT products and services". It is a long standard. It has fourteen clauses, eight annexes and hundreds of testable requirements. The requirements cover hardware, software, web pages, documents and support services.
Clause 4 is the short part that explains why the rest exists. Annex E.3 calls it "the heart of the standard". Clause 4 contains eleven functional performance criteria. Each one is a plain statement of what a group of users needs to be able to do. Users need to use the information and communication technology (ICT):
- without vision
- with limited vision
- without perceiving colour
- without hearing
- with limited hearing
- without speaking
- with limited manipulation or strength
- with limited reach
- without seizure triggers
- with limited cognition, language or learning
- without giving up privacy.
The same eleven needs appear in the European Accessibility Act (EAA). They are points (a) to (k) of Annex I Section VII, in the same order. The EAA also calls them functional performance criteria.
This lesson explains four things:
- how the standard words the criteria
- how the criteria relate to the technical requirements in clauses 5 to 13
- what "permanent, temporary or situational" means
- how the Directive uses the criteria as a safety net when its specific requirements do not reach a function.
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Sources
- ETSI, CEN and CENELEC, EN 301 549 V4.1.1 (2026-09), clause 4 (4.1 and 4.2.1 to 4.2.11), Annex B (Tables B.1 and B.2, clause B.2), Annex C and Annex E.3, available from the ETSI standards server.
- Directive (EU) 2019/882 (the European Accessibility Act), EUR-Lex, Annex I Section VII, points (a) to (k) and its two opening paragraphs.
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2 and Understanding WCAG 2.2 for Success Criteria 1.4.1, 2.1.1, 2.3.1 and 2.5.7.
- Accessibility Checker: Using Accessibility Checker with VoiceOver (iPhone and iPad) and The Lens: color-blindness simulation (Mac).
