Official Sync:2026-03-15

Public Sector (WAD / EAA Overlap) Hub

Public sector bodies are subject to both the Web Accessibility Directive (WAD, 2016/2102) and — where they offer EAA-scope services commercially or in competition with the private sector — the EAA. Understanding which regime applies, where they overlap, and how monitoring and enforcement interact is critical for compliance officers.

Compliance Deadline

WAD: Already in force (websites since 2019, apps since 2021). EAA: 28 June 2025 for in-scope services.

Who This Applies To

National, regional, and local government bodies; public universities; state-owned enterprises providing EAA-scope services; bodies governed by public law; entities receiving primarily public funding.

Legal Basis

›Web Accessibility Directive (Directive 2016/2102)
›European Accessibility Act (Directive 2019/882)
›EN 301 549 v3.2.1 (normative technical standard for both directives)

Key Standards

›WCAG 2.2 Level AA
›EN 301 549 v3.2.1 (full scope)
›PDF/UA-1 (ISO 14289-1)
›Open Document Format / OOXML accessibility

Compliance Requirements

Public Procurement & ICT Tenders

Under EN 301 549 (referenced in EU public procurement rules), all ICT products and services procured by public bodies must meet EN 301 549. Tender specifications must include accessibility requirements as mandatory technical criteria, not optional add-ons. Evaluation panels must include accessibility expertise. Contracts must include accessibility acceptance testing provisions and remediation obligations.

WAD Accessibility Statements

All public sector websites and mobile apps must publish an accessibility statement compliant with Commission Decision (EU) 2018/1523 (the model template). The statement must declare conformance status (fully / partially / non-conformant), list known issues with estimated resolution dates, describe the feedback mechanism, and link to the enforcement body. Statements must be reviewed at least annually.

WAD Monitoring & National Reporting

Member States must monitor public sector website and app accessibility under the WAD monitoring methodology (simplified monitoring via automated tools; in-depth monitoring via user testing). Results must be reported to the European Commission every 3 years. Public sector bodies should expect audit by national monitoring bodies and maintain audit-ready documentation.

EAA Market Surveillance Integration

Where public sector bodies provide EAA-scope services (e.g., a state-owned transport operator or bank), they are subject to EAA market surveillance in addition to WAD monitoring. Market surveillance authorities may conduct inspections, request documentation, and issue corrective orders. Non-compliant services can be withdrawn from the market or restricted.

Accessible Documents & Information

Government documents published digitally (policies, guidance, consultation responses, forms, annual reports) must be accessible. PDFs must be tagged and pass PDF/UA validation. Word/Excel documents shared publicly should be structured accessibly. HTML equivalents should be provided for complex documents where PDF accessibility is technically insufficient.

Digital Public Services & Portals

Citizen-facing digital services — tax portals, benefits applications, permit renewals, electoral registration, health appointment booking — must comply with WCAG 2.2 Level AA at minimum. Services involving complex workflows (multi-step forms, file uploads, identity verification) must be tested with assistive technology users, not just automated tools.

Feedback Mechanisms & Enforcement Routes

Public bodies must maintain an accessible feedback mechanism (form or email) through which users can report accessibility issues or request accessible formats. Responses must be provided within a reasonable timeframe (typically 30 days). If the body fails to respond or remedy issues, users must be able to escalate to the national enforcement body — a link to which must appear in the Accessibility Statement.

Practical Steps to Compliance

1
Review all current Accessibility Statements — update non-conformant items with realistic resolution dates
2
Integrate EN 301 549 as a mandatory requirement in all current and upcoming ICT tender specifications
3
Run an automated WAD monitoring scan on your top 20 most-visited pages before the next monitoring period
4
Create a document accessibility policy for all staff producing public-facing content
5
Map which of your services fall under EAA scope as well as WAD — assign owners for each
6
Establish a cross-department accessibility working group with sign-off authority
7
Train procurement officers on ICT accessibility evaluation criteria

Exemptions & Proportionate Burden

WAD exempts content published before 23 September 2018 unless substantially revised; live broadcasts; online maps (with accessible alternatives); third-party content not funded or controlled by the public body; intranets and extranets published before June 2019 (unless substantially revised). EAA exempts microenterprises for product requirements.

Generate the mandatory accessibility statement required by the Web Accessibility Directive.

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Important Legal Disclaimer

This tool is a self-assessment aid only and does not constitute legal advice or a formally certified compliance assessment. Outputs — including reports, scores, checklists, and accessibility statements — are for internal use and should be reviewed by a qualified legal representative or independent accessibility auditor before being relied upon for regulatory, procurement, or public-disclosure purposes. All assessment risk lies with the internal assessor. accessibilityref, its developers, and staff accept zero liability for losses arising from use of or reliance on these outputs. Always verify against official sources: the W3C WCAG 2.2 Recommendation, the European Accessibility Act (Directive 2019/882), and your national enforcement authority.