Section 508 vs EN 301 549 (2026) | US and EU Accessibility Standards

Last updated: 2026-07-10

Section 508 and EN 301 549 are the two big government accessibility standards on either side of the Atlantic, and any organization that sells software, documents, or digital services into both the United States and the European Union eventually has to understand how they relate. Section 508 is part of the US Rehabilitation Act; its 2017 refresh requires US federal agencies — and the vendors who sell to them — to make their information and communication technology accessible, and for web content it incorporates WCAG 2.0 Level A and AA by reference. EN 301 549 is the European harmonized standard for accessible ICT; its current version references WCAG 2.1 Level A and AA and underpins both the EU Web Accessibility Directive for public-sector bodies and, increasingly, the European Accessibility Act that now reaches many private companies. Both standards go well beyond websites: they also cover software, hardware, electronic documents, and support services, and both lean heavily on WCAG for the web portion. But they differ in which WCAG version they cite, exactly who is legally bound, and how broad the surrounding ICT requirements are. This comparison lays out those differences in plain terms so you can see what it takes to satisfy both at once.

At a Glance

Feature Section 508 EN 301 549
Jurisdiction United States (federal government ICT) European Union (harmonized across member states)
Legal basis Section 508 of the Rehabilitation Act (36 CFR Part 1194) EU Web Accessibility Directive and the European Accessibility Act
WCAG version referenced (web) WCAG 2.0 Level A and AA WCAG 2.1 Level A and AA
Who must comply US federal agencies and their vendors/contractors EU public-sector bodies, plus many private firms under the EAA
Scope beyond web Software, hardware, documents, support services Software, hardware, documents, support — with dedicated chapters per ICT type
Standard conformance document VPAT / Accessibility Conformance Report (ACR) Accessibility statement (public sector); EAA-style declarations for products
Practical web target Meet WCAG 2.0 AA Meet WCAG 2.1 AA (superset of 2.0 AA)

Section 508

Type: US federal standard under the Rehabilitation Act (1998 amendment, refreshed 2017) governing accessible ICT bought, built, or used by federal agencies Pricing: Free to read — it is a published US federal regulation (36 CFR Part 1194). Best for: Vendors selling technology to the US federal government, and anyone who needs to produce a VPAT for US procurement.

Pros

  • Well established in the US: federal agencies and their contractors have followed it for years, with mature procurement processes around it
  • For web content it maps cleanly onto WCAG 2.0 Level A and AA, so meeting that WCAG version covers the web portion
  • Uses the VPAT (Voluntary Product Accessibility Template) as the standard way for vendors to document conformance
  • Covers ICT broadly — software, hardware, electronic documents, and support — not just web pages

Cons

  • Technically binding only on US federal agencies and their suppliers, not on typical private businesses (though it is often cited contractually)
  • Still references the older WCAG 2.0, so it lags behind the mobile and low-vision improvements in WCAG 2.1 and 2.2
  • State and local government (Title II) accessibility is governed separately by the ADA, which now references WCAG 2.1 AA — so 508 alone is not the whole US picture
  • The web requirements are only as current as the WCAG version it cites, which is now several years behind

EN 301 549

Type: European harmonized standard for accessible ICT (current version V3.2.1, 2021), maintained by ETSI, CEN, and CENELEC Pricing: Free to download from ETSI — it is a published European standard. Best for: Any organization selling products or services in the EU, especially those now in scope of the European Accessibility Act.

Pros

  • References the newer WCAG 2.1 Level A and AA, so it captures mobile, reflow, and low-vision requirements that 2.0 misses
  • Underpins two major legal frameworks: the EU Web Accessibility Directive (public sector) and the European Accessibility Act (much of the private sector)
  • Comprehensive ICT scope, with dedicated chapters for web (Chapter 9), documents (Chapter 10), and software (Chapter 11), plus hardware and biometrics
  • Harmonized across all EU member states, giving a single technical target for the whole single market

Cons

  • Broader and more detailed than a pure web standard, so the full document can feel heavy if you only run a website
  • The referenced WCAG version has lagged updates in the past, and alignment to WCAG 2.2 is still working through the standards process
  • Legal obligations flow through several instruments (the Directive, the EAA, and national laws), so who must comply depends on your sector and role
  • Conformance documentation practices are less uniform than the US VPAT, though EU-style accessibility statements are expected for public-sector sites

Our Verdict

Section 508 and EN 301 549 are cousins, not opposites: both are government ICT standards that borrow WCAG for their web requirements, both cover far more than websites, and both use a conformance document to prove compliance. The two practical differences that matter are the WCAG version and who is bound. Section 508 references WCAG 2.0 Level AA and applies to US federal agencies and their suppliers, documented with a VPAT. EN 301 549 references the newer WCAG 2.1 Level AA and applies across the EU — to public-sector bodies under the Web Accessibility Directive and to a growing set of private companies under the European Accessibility Act. Because WCAG 2.1 is backward compatible with 2.0, the good news is that a single well-built site can satisfy both: if you meet WCAG 2.1 Level AA, you cover EN 301 549's web requirements and comfortably exceed Section 508's WCAG 2.0 baseline. Our advice for anyone selling into both markets is to build and test to WCAG 2.1 AA as the common denominator, then produce the documentation each side expects — a VPAT/ACR for US federal procurement and an accessibility statement for EU public-sector work. That way the underlying engineering is done once, and only the paperwork differs. This is general guidance, not legal advice; confirm your specific obligations with a qualified professional.

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