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EAA A11y Hub

Clause 11 — Software

Clause 11 is the software equivalent of Clause 9 — it covers native mobile apps, desktop applications, and operating systems, restating WCAG-equivalent success criteria in software terms via the “WCAG2ICT” mapping.

What it covers

  • Platform accessibility APIs — the software must correctly expose its UI through the platform's accessibility layer, so tools like VoiceOver, TalkBack, and desktop screen readers can interpret it.
  • Keyboard and switch-equivalent operability — all functionality must be operable without a mouse or touch alone.
  • Closed functionality — software with genuinely no accessible interface (some dedicated ticket-machine software, for example) still needs an alternative means of access, per Clause 5.
  • Includes web apps that behave like software (e.g. complex single-page applications), alongside the web-content requirements of Clause 9.

Who this applies to

Native mobile apps, desktop applications, and operating systems in scope of the EAA and the Web Accessibility Directive's mobile app requirements.

For the fuller narrative on native apps, kiosks and related non-web scope, see the Non-web overview.

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.