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Clause 10 — Non-web documents

Clause 10 extends WCAG-equivalent requirements to electronic documents that aren't themselves web pages, but are distributed as part of a product or service — a downloadable PDF report, a Word contract template, an ePub, a spreadsheet.

What it covers

  • Structure and tagging — documents need real structural markup (headings, lists, tables) rather than purely visual formatting, so assistive technology can navigate and interpret them.
  • Reading order — content must have a sensible, programmatically determinable reading order, especially for multi-column or form-heavy layouts.
  • Text alternatives — images and non-text content need alt text; purely decorative elements should be marked as such.
  • Form fields — interactive form fields (in a fillable PDF, for example) need labels and must be operable via keyboard and screen reader.
  • Applies across common formats: PDF, Word/OpenDocument, ePub, spreadsheets, and similar.

Who this applies to

Any organisation distributing documents as part of a product or service in scope of the Web Accessibility Directive or the EAA — including documents linked from an otherwise-compliant website.

Read the standard

This page is a plain-language summary, not the normative text. For the full requirement wording, see EN 301 549 V3.2.1 (2021-03) directly:

Download EN 301 549 V3.2.1 (PDF, ETSI)

V3.2.1 (WCAG 2.1 AA) is the version cited in the EU Official Journal and currently has legal effect for EAA presumption of conformity. A newer edition, V4.1.1 (WCAG 2.2 AA), has been published but is not yet cited — see what's coming in V4.1.1 for what's changing and when it's expected to take effect.