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Clause 5 — Generic requirements

Clause 5 sets out baseline requirements that apply broadly across ICT products and services, independent of whether they're delivered as a website, an app, or a physical device. Later clauses (6–13) layer more specific requirements on top, depending on what the product actually does.

What it covers

  • Closed functionality — where a product's interface genuinely can't be made accessible through built-in means (for example, some single-purpose ticket machines), Clause 5 requires an alternative way to access the same functionality.
  • Biometrics — where a product uses biometric authentication (e.g. fingerprint or face recognition) as the only way to operate it, an alternative method must be available for people who can't use that biometric method.
  • Privacy — accessibility features (such as text-to-speech readback of a PIN) must not compromise a user's privacy or security any more than the standard, non-accessible method does.
  • Non-visual and visual access — operable parts, status indicators and controls must be identifiable and usable both visually and non-visually, not relying on a single sense.
  • Colour and contrast — colour must not be the only way information is conveyed, and text/background contrast must meet minimum ratios.
  • Operable parts — controls must be reachable and operable without requiring fine motor control, simultaneous actions, or tight grasping and twisting.

Who this applies to

Effectively every ICT product or service in scope of the Web Accessibility Directive or the EAA picks up at least some Clause 5 requirements — it's the common baseline sitting underneath the web/software/hardware-specific clauses.

Read the standard

This page is a plain-language summary, not the normative text. For the full requirement wording, see EN 301 549 V4.1.1 (2026-09) directly:

Download EN 301 549 V4.1.1 (PDF, ETSI)

V4.1.1 is the newest published edition, aligned with WCAG 2.2 AA. It is not yet cited in the EU Official Journal, so V3.2.1 (WCAG 2.1 AA) remains the version with current legal effect for EAA presumption of conformity — see the timeline for the expected citation date.