WCAGpilot
Check a site
Sign in

The Web Accessibility Directive (WAD)

Directive (EU) 2016/2102 is the EU's accessibility regime for public-sector websites and mobile apps. Adopted on 26 October 2016 with a transposition deadline of 23 September 2018, it rolled out in stages: new sites from September 2019, existing sites from September 2020, mobile apps from 23 June 2021. It binds 32 jurisdictions (27 EU + Norway, Iceland, Liechtenstein, plus the UK's pre-Brexit transposition; Switzerland sits outside).

Adopted
26 October 2016
Scope
Public sector only
Standard
EN 301 549 / WCAG 2.1 AA
Jurisdictions
32 implement — 27 EU + Norway, Iceland, Liechtenstein + UK (pre-Brexit transposition). Switzerland sits outside.

What WAD covers

The directive reaches websites and mobile applications of public-sector bodies. The definition is wide:

  • The State, regional and local authorities
  • Bodies governed by public law (universities, hospitals, transport agencies)
  • Associations formed by one or several of the above

Article 1(4) carves out a handful of exclusions: archived content untouched since the rolling deadlines, pre-recorded time-based media published before 23 September 2020, third-party content outside the body's control, and reproductions of items in heritage collections.

The private sector sits outside WAD. Private-sector accessibility falls under the European Accessibility Act (EAA), which has applied since 28 June 2025.

The technical standard, EN 301 549

Commission Implementing Decision (EU) 2018/2048 designates EN 301 549 as the harmonised standard. Conformance with it creates a presumption of compliance.

EN 301 549 incorporates WCAG 2.1 Level AA for web content and adds clauses on software, hardware and documents. The applicable version is V3.2.1 (2021-03). The September 2023 WCAG 2.1 revision, which removed SC 4.1.1 ("Parsing"), feeds into 2024 and later monitoring cycles.

Several Member States layer national technical references on top:

  • France, RGAA (Référentiel général d'amélioration de l'accessibilité): 106 criteria, 255 tests.
  • Luxembourg, RAWeb: 136 criteria (replaced RGAA from 2024), plus raam for mobile.
  • Germany, BITV 2.0: adds PDF/UA checks via Sondermonitoring and pulls in sign-language and Easy Language requirements.

Rolling deadlines

Compliance phased in over three years:

  • 23 September 2018, transposition deadline for Member States.
  • 23 September 2019, new public-sector websites in scope (sites launched on or after 23 September 2018).
  • 23 September 2020, all existing public-sector websites in scope.
  • 23 June 2021, public-sector mobile apps in scope.

EEA states ran on a deferred timetable. Norway brought the regime into force on 1 February 2022. Iceland still hasn't transposed: the EFTA Court declared Iceland in breach in Case E-10/25 on 9 December 2025, more than 18 months after the 1 April 2024 deadline expired.

Accessibility statements

Article 7 requires every public-sector body to publish an accessibility statement covering:

  1. Compliance status (full, partial, non-compliance)
  2. Inaccessible content with reasons (non-compliance, disproportionate burden, out of scope)
  3. A feedback mechanism for users
  4. A link to the national enforcement procedure

Commission Implementing Decision (EU) 2018/1523 sets the baseline template. Most Member States bolt national extensions onto it.

Monitoring and reporting

Member States monitor compliance under Commission Implementing Decision (EU) 2018/1524. The methodology runs on three tiers:

  • In-depth monitoring, full WCAG-EM-style audits on a sample.
  • Simplified monitoring, automated checks with light manual review on a larger sample.
  • Mobile-app monitoring, increasingly folded in (France formally defers this).

Triennial reports go to the Commission. Two cycles have closed so far: 2020–2021 and 2022–2024. The country reports sit on the Commission portal.

Enforcement

Enforcement is decentralised, and the gap between regimes is wide. Four broad patterns:

  • Active fines. Sweden (DIGG, 175 formal notices in 2025), Slovakia (€500 to €35,000 per breach), France (ARCOM fines up to €50,000 from 2024), Norway (daily tvangsmulkt).
  • Ombudsman and mediation. Latvia (Tiesībsargs), Ireland (Office of the Ombudsman), Italy (Difensore Civico per il Digitale at AgID), Luxembourg (SIP).
  • Decentralised and federated. Germany (one federal body plus 16 Länder), Austria (one federal plus nine Länder), Belgium (federal plus regional and community).
  • Advisory only, no fines. Hungary (zero procedures on record), Poland (no fines regime), Estonia (action plans).

Sweden is the outlier on volume. Norway runs the most aggressive coercive-fine regime in the EEA. Most other countries have the legal tools but rarely use them. See the full enforcement picture →

How each country implements WAD

Every country page lists the national transposition act, the monitoring body, the technical reference, the statutory response time, and the country-specific extras.

Browse by country →