While EN 301 549 is the technical standard cited in the European Accessibility Act (EAA), EN 17161 Design for All is a framework that supports embedding accessibility into strategy, design, and development processes.
Both are harmonised standards used by the EAA and yet all the focus has been on EN 301 549. This post explores how the two standards relate to each other, and what that means for providers of digital products and services.
Sustainable accessibility: an outline of a muted purple tree with two branches on either side of the trunk. At the ends of the branches are bright purple or red gears which interlock and rotate with the gear above or below it. There are two bright orange leaves growing at the top of the tree and a single leaf towards the bottom.
Sustainable accessibility
In brief
As outlined in Understanding the EAA by Léonie Watson, we interpret the EAA's requirements for digital products and services to mean that economic operators and service providers should take the following steps to maximise their conformance with the Act:
Use EN 17161 Design for All to put in place processes and practices that enable continuing conformance with the accessibility requirements
Use EN 301 549 and the functional performance criteria in Annex I to demonstrate conformance with the accessibility requirements
Document how services conform to the accessibility requirements, and how processes and monitoring help achieve conformance
If warranted, carry out a disproportionate burden assessment, and report to all national authorities where the product or service is available if an exemption is claimed
For the purposes of this post, we will refer to EN 17161 Design for All, as Design for All.
Availability
Design for All is a paid for standard available from a number of places at a range of prices.
Purpose
The purpose of Design for All is to help organisations embed accessibility into their management systems, ensuring that accessibility is considered from strategy and planning through to implementation and review.
Scope
Design for All is applicable to all organisations regardless of type, size or sector. It supports making products, goods, services, and environments accessible and usable by as many people as possible, including disabled and older people.
Key points
Focus
Design for All is a framework of process requirements that complements EN 301 549, the technical standard referenced in the EAA. As such it emphasises how to integrate accessibility considerations into seven areas which are outlined in clauses 4 to 10:
Context of the organisation
Leadership
Planning
Support
Operation
Performance evaluation
Improvement
User involvement
Design for All has a strong emphasis on the importance of involving a diverse range of people, particularly people with disabilities, in the design and evaluation process.
This is covered in detail in Annex C where it describes including people with disabilities in the design process in the following ways:
1. Understand who will use it and how
Understand who your audience is and in what situations they'll be using the product or service.
2. Learn what users need and want
Get a clear picture of what matters to people, including their goals, preferences, abilities, and limitations, so these can shape the design and requirements.
3. Design something that works for them
Create solutions that match what people need and expect, based on what you've learned.
4. Check if it actually works for users
Test the solution with people to see if it meets their needs and works well for them, and check whether it matches the original goals.
Compatibility
The Design for All approach is intended to align with other management system standards such as ISO 9001, making it easier for organisations already following such frameworks to incorporate accessibility.
Supports compliance with the EEA
EN 17161 Design for All, is already a recognised standard that can be used to demonstrate conformance with the EAA. A revised version is planned for publication in September 2025.
Clauses and requirements
Clauses 4 to 10, describe areas an organisation can focus on in order to adopt the Design for All approach.
Clause 4: Design for All approach
The Design for All approach focuses on how organisations can embed accessibility into their operations. It sets the foundation for making accessibility a consistent part of strategy, design, and delivery, particularly in the context of digital and physical products, services, and environments.
Clause 4.1: Accessibility following a design for all approach
Design for All is about making products and services work for as many people as possible including older people, and different types of disability including people with seeing, hearing, moving, or thinking disabilities.
It means thinking about accessibility and usability from the very beginning, and keeping it in mind through every stage of the product or service lifecycle.
The Design for All approach doesn't mean everything has to be identical for everyone. It means making sure people can:
Access it: find it and take it in
Understand it: know what it's for and what to do
Use it: take action or respond in their own way
In short, it's about flexibility, not uniformity, so everyone gets a comparable experience, in a way that works for them.
Clause 4.2: Understanding the organisation and it's context
Organisations should make sure that all relevant policies, processes, and activities follow a Design for All approach. To do this well, they need a clear understanding of how their internal and external environments affects accessibility.
This includes:
User needs and preferences: what people require to access, understand, and use products and services
Feedback on existing products and services: what people are telling you about barriers and improvements
Legal and regulatory duties: national and international requirements for accessibility
Competitor practices: how others in the sector are addressing accessibility
Compatibility with assistive technologies: ensuring products work with tools people rely on
Changes in technology: keeping pace with new platforms, devices, and trends
Supply chain capability: what partners and suppliers can deliver in terms of accessibility
Economic, social, and cultural factors: broader issues that shape how people engage with your organisation
Clause 4.3: Understanding the needs and expectations of interested parties
Organisations should identify who uses their products and services, who is excluded, and why.
Organisations should:
Identify who uses the product: including those who use the product or service directly, and those who support others to use it
Understand who is not using it: especially where accessibility may be a barrier
Plan for inclusion: identify what needs to change to help more people access, understand, and use the product or service
Consider delivery needs: take into account the needs of anyone involved in delivering or supporting the service
Review regularly: keep this information up to date as things change
Clause 4.4: Determining the scope of the Design for All approach within the organisation
Organisations should decide how and where their Design for All approach will apply.
Organisations should consider:
Internal and external factors: identified in Clause 4.2
People's needs and expectations: described in Clause 4.3
Clause 4.5: Integration with established process systems
Design for All works best when it's part of everyday practice, not treated as an add-on. To make this happen, accessibility should be built into existing processes and systems.
Organisations should:
Understand and address accessibility needs: make sure everyone knows what's required and why it matters
Recognise the value of inclusion: help all teams see the benefit of reaching more people
Embed accessibility into all processes: from design and development to delivery and support
Use feedback and data: learn from real experiences to improve products and services over time
Clause 5: Leadership
Leaders play a critical role in making accessibility part of how an organisation works. They need to set the vision, define policies, assign responsibilities, and provide the support and resources needed. A strong, well communicated commitment from the top makes it more likely that accessibility will be built into every part of the organisation.
Clause 5.1: Leadership and commitment
Senior leaders in the organisation must show clear commitment to accessibility by creating an accessibility vision and goals to inspire employees and provide clear goals to measure progress against.
Leadership should show their commitment to accessibility by:
Investing in accessibility: providing enough time, money, and people
Setting clear goals: defining targets and how success will be measured
Making responsibilities clear: assigning ownership across teams
Embedding accessibility into culture: encouraging everyone, from planning and design to marketing to take part
Creating space for innovation: supporting new ideas to improve accessibility and reach more people
Supporting continuous improvement: reviewing progress and identifying areas to grow
Monitoring activity: keeping track of design and development decisions
Linking accessibility to brand and reputation: using accessibility as a way to build trust and reach more customers
Building capability: identifying training needs and recruiting people with the right skills
Making accessibility happen takes both a top-down and bottom-up effort. Product teams can lead the way, but real impact depends on strong support from leadership. Senior decision makers play a critical role in setting direction, removing barriers, and making accessibility part of how things are done.
Clause 5.2: Policy
Leadership should create an accessibility policy that:
Shows commitment: focuses on improving access, understanding, and use by people with disabilities
Applies across the organisation: is scoped to be used across all teams, products, and services
Drives continuous improvement: supports learning and progress over time
Fits the organisation's purpose: is aligned with goals, values, and the business context
Gets reviewed regularly: is updated when things change or new needs emerge
Is shared openly: is understood by everyone inside the organisation, and outside, when relevant
Leadership should clearly assign and communicate responsibility for accessibility by:
Defining accountability: making it clear who is responsible for improving accessibility and reaching more users
Checking effectiveness: making sure accessibility efforts are working as intended
Keeping users in focus: ensuring all teams consider a wide range of user needs
Building understanding: helping staff recognise the value of designing for different characteristics, abilities, and preferences
Clause 6: Planning
Planning for accessibility means thinking about risks, opportunities, goals, and changes. Organisations should set clear objectives, build accessibility into all relevant processes, and be ready to adapt while protecting accessibility outcomes. A planned, proactive approach ensures more people can use products and services effectively, now and in the future.
Clause 6.1: Actions to address risks and opportunities
When planning a Design for All approach, organisations should consider internal and external factors (clause 4.2) and user needs and expectations (clause 4.3) to:
Support accessibility goals: make sure policies and processes can deliver what's needed
Avoid problems: reduce the risk of missing user needs or accessibility targets
Use opportunities: find ways to attract new users or explore new service areas
Reach more people: keep expanding who can access, understand, and use products and services
Organisations should also:
Plan specific actions: address risks and opportunities directly
Embed actions into everyday work, including:
recruitment and hiring
disability knowledge and lived experience
user involvement and feedback
product and service design
manufacturing and delivery
work with external providers
packaging and presentation
Evaluate impact: check how well actions are working
Track barriers: collect and review information on what prevents people from accessing, understanding, or using the organisation's products and services
Clause 6.2: Design for All approach objectives and planning to achieve them
Organisations should set clear accessibility goals across relevant teams and levels that:
Align with the vision and policy: reflect the organisation's purpose (clause 5.2)
Are measurable: define clear outcomes where possible
Meet requirements: cover both legal and organisational needs
Are tracked and reviewed: checked regularly to monitor progress
Are clearly communicated: shared across the whole organisation
To meet these goals, organisations should plan:
What needs to happen: define the specific actions
What resources are needed: identify time, money, and people
Who is responsible: assign clear accountability
When it will happen: set realistic timelines
How success will be measured: agree what good looks like
Clause 6.3: Planning for changes
Organisations should plan for any changes that could affect accessibility or their Design for All approach.
Changes to policies, processes, or activities must be managed carefully and with a clear plan (clauses 4.2 and 4.3).
When planning changes, organisations should:
Understand the reason for change: know why it's needed and how it could affect people
Assess the potential impact, including:
The overall Design for All approach
The accessibility of products and services
Check available resources: identify what time, people, or budget will be needed
Review roles and responsibilities: decide if any changes are needed in who does what
Clause 7: Support
Organisations need to put the right resources, skills, communication, and documentation in place to support their Design for All approach. This means making sure teams are informed, trained, and equipped. And that decisions and actions are clearly recorded and reviewed.
Clause 7.1: Resources
Organisations should provide the right resources to support a Design for All approach and meet accessibility goals. This means making sure the right people, tools, and systems are in place at every stage.
Organisations should:
Review what's already in place: assess internal skills, tools, and infrastructure
Identify what's missing: decide what support or expertise is needed from outside
Make use of existing knowledge: identify and apply what's already known about accessibility and inclusion
Support inclusive design infrastructure: build and maintain systems that make accessible ways of working possible
Match resources to each stage: identify resources for design through to delivery and monitoring
Fund measurement and tracking: allocate time and money to measure progress and impact
Clause 7.2: Competence
Organisations should make sure everyone involved in Design for All has the right knowledge, skills, and experience. This helps teams make informed decisions and deliver accessible outcomes.
Organisations should:
Identify required skills: understand what capabilities are needed across roles
Provide ongoing training: keep staff up to date with regular learning and development
Clause 7.3: Awareness
Everyone involved, including employees and suppliers, should understand their role in supporting a Design for All approach. Clear communication helps build shared responsibility and sustained progress.
Organisations should make sure people are aware of:
The vision and policy: as set out in clause 5.2
Accessibility objectives: defined in clause 6.2
Their role and responsibilities: how they contribute to an inclusive culture
Performance feedback: how well their work supports accessibility outcomes
Clause 7.4: Communication
Organisations should plan how they communicate about Design for All and accessibility, both internally and externally. Good communication builds awareness, accountability, and trust.
Organisations should:
Decide what to share: choose the most relevant and useful information
Plan when and how to share it: use the right timing and channels for each audience
Identify who needs to know: make sure the right people receive the right messages
All communication should be clear and accessible.
Clause 7.5: Documented information
Organisations should create and maintain key documents that support their Design for All approach. These documents help track progress, guide decisions, and show accountability.
Organisations should include documentation that covers:
Interested parties and their needs: who uses their products and services as outlined in Clause 4.3
The scope of the approach: where and how Design for All applies (clause 4.4)
The vision and policy: setting direction and intent (clause 5.2)
Accessibility goals: what the organisation aims to achieve (clause 6.2)
Supporting processes: systems in place to deliver on accessibility (clause 8.1)
User needs in design: how people's requirements are included (clause 8.2.3)
Accessibility evaluations: how accessible products and services are assessed (clause 8.2.5)
Accessibility across the user journey: from start to finish (clause 8.4)
Monitoring and measurement: how progress is tracked (clause 9.1)
The assessment process: and the outcomes (clause 9.2)
Decisions and actions for improvement: what's been done in response (clause 9.3)
Updates and improvements: any changes made over time (clause 10)
Other relevant documentation: anything else the organisation deems necessary
Clause 8: Operation
Accessibility needs to be part of every stage of a product or service, from design through to launch. Organisations should understand who their users are, include them early on, and think about their needs at each step. Testing, clear communication, and working closely with suppliers all help make sure the whole user journey is accessible.
Clause 8.1: Operation planning and control
Organisations should embed Design for All into everyday operations. This helps make accessibility a consistent part of how work gets done.
Organisations should:
Set clear ways of working: define rules and expectations
Check regularly for consistency: make sure teams follow agreed processes
Manage change: plan for changes and respond to unexpected issues (clause 6.3)
Hold suppliers to the same standard: ensure external partners meet accessibility requirements
Clause 8.2: Design and development of products and services
Clause 8.2.2: Identifying the intended users
Clause 8.2.2.1: Establishing users and non-users
Organisations should understand who can, and can't, use their products and services. This helps identify barriers and uncover opportunities to improve accessibility.
Organisations should:
Identify who is and isn't using what they offer: including direct and indirect users
Find out why some people are excluded: collect insights from those affected through user research, usability testing, and feedback loops
Use multiple sources: look at internal data and external research
Analyse the information: organise and curate insights and use them to fill any knowledge gaps
Clause 8.2.2.2: Specifying the intended users
Organisations must clearly define who the intended users are, making sure this includes the widest possible range of people, including those who access products indirectly for example through another person or device.
Clause 8.2.2.3: Identifying the needs, characteristics and capabilities of the intended users
Organisations must:
Recognise diverse user needs: consider differences in age and physical, sensory, mental, and cognitive capabilities
Identify the context of use: including location, environment, and typical tasks
Understand the relationship between needs and context: how different environments and situations affect what people need from a product
Clause 8.2.3: Requirements to extend the range of users
Design specifications must include:
User requirements: based on identified user needs
Legal and regulatory requirements: including relevant laws and regulations
Applicable standards and guidance: such as accessibility and usability standards
Information on barriers and assistive technologies: to help reduce or remove barriers
Compatibility with assistive technology: including interoperability considerations
Insights from earlier analysis: drawing on findings from user research (clause 8.2.2)
Clause 8.2.4: Realisation
Clause 8.2.4.1: Developing solutions
Organisations should:
Use reliable user information: based on evidence rather than assumptions
Follow best practices: in accessibility and inclusive design
Gather and apply user feedback: including feedback from people who use assistive technologies
Use an iterative design process: test, improve, and repeat
Ensure equal treatment: for people who use assistive technologies
Maximise compatibility: by using open standards that support assistive technology
Clause 8.2.4.2: Approaches to design solutions to achieve accessibility outcomes
Designs should:
Offer multiple ways to interact: so people can access and use content in different ways
Support flexibility:so people can adjust the design to suit their needs
Reduce complexity: by keeping interactions simple and avoiding unnecessary steps
Enable personalisation: so people can tailor access to their needs
Avoid unnecessary limits: that restrict how people interact with the product
Be compatible with assistive technology: ensuring smooth use with a wide range of hardware and software
Clause 8.2.5: Evaluation
Organisations must evaluate their products and services to check they meet accessibility goals.
This includes reviewing:
Early concepts: to identify issues from the start
Prototypes: to test ideas before development progresses
Technical specifications: to ensure accessibility is built into the foundations
Design alignment: checking how well the product matches its intended design
Usability testing with disabled people: to understand real-world accessibility
Testing and evaluation should take place during development and between product versions.
Clause 8.3: User involvement
Organisations must involve disabled people as early as possible in design and development.
This includes:
Identifying user needs and preferences: to shape inclusive solutions from the start
Gathering feedback on barriers and opportunities: to understand what helps or hinders access
Identifying relevant assistive technologies: that people use to interact with products
Involving users in testing and evaluation: to check how well the design works in practice
Clause 8.4: End-to-end chain in relation to accessibility
Organisations must think about accessibility across the whole user journey, not just the product itself. This means identifying:
Where the biggest barriers exist: across different stages of the journey
How mature each part is: in terms of accessibility readiness
Who controls each stage: whether internal teams or external partners
How external factors affect access: such as packaging, instructions, and customer support
Both internal and external factors should be reviewed, including:
Pre-sale and purchase: how people find, choose, and buy the product
Installation and setup: how easily the product can be put into use
Post-sale support and warranty: how help and repairs are handled
The organisation must assess these factors and use the findings to support:
Stakeholder needs: as outlined in clause 4.3
Scope definition: as outlined in clause 4.4
Planning and design: as outlined in 6.1, 6.2, and 8.2
Evaluation and improvement: as outlined in 8.2.5, 9.1, and 9.2
Clause 8.5: Control of and communication with external suppliers
Organisations must set clear accessibility and usability requirements for suppliers and communicate:
What is expected: outlining their responsibilities clearly
How they contribute: to meeting end-to-end accessibility
This helps ensure that externally sourced products or services still support the organisation's accessibility vision and goals.
Clause 9: Performance evaluation
Organisations need to keep checking how well their Design for All approach is working. This includes measuring what's happening, listening to users, and tracking progress. Regular internal checks and reviews by leaders help make sure the organisation stays on track and makes products and services more accessible to more people over time.
Clause 9.1: Monitoring, measurement, analysis and evaluation
Clause 9.1.1: General
Organisations must regularly monitor, measure, analyse, and evaluate how well their Design for All approach is working.
This helps them check if they are:
Meeting accessibility goals: by tracking progress against targets
Following planned processes: to maintain consistency and quality
Achieving intended results: by measuring impact on users
They must:
Decide what to monitor and measure: linked to the organisation's policy (clause 5.2) and objectives (clause 6.2)
Use reliable methods: to collect and assess meaningful data
Check real-world access and use: whether products and services are being accessed, understood, and used by as many people as possible
Evaluate effectiveness: using the results to assess how well the Design for All approach is working
Monitoring helps track whether more people are able to use a product or service and where improvements may be needed (clause 10).
Clause 9.1.2: User feedback
Organisations must collect feedback from users, including people with disabilities, to understand whether their needs are being met.
This includes:
Involving a diverse group: especially people who may not usually take part
Offering multiple feedback options: such as online, phone, or in-person
Using feedback to improve: policies, processes, and products
Clause 9.1.3: Analysis and evaluation
Organisations must analyse the data they collect to:
Show compliance: demonstrating that products and services meet Design for All requirements
Improve customer satisfaction: by responding to real user experiences
Assess effectiveness: checking how well the overall approach is working
Review supplier performance: evaluating how well external partners are delivering
Identify process improvements: finding areas that need change or refinement
The results from this analysis feed into management decision-making and help guide further actions.
Clause 9.2: Internal audit
Organisations must evaluate its own processes and systems regularly to check whether:
Practices match policies: ensuring alignment with their own Design for All commitments
Requirements are met: confirming compliance with this standard
The approach is maintained: checking that it's being properly followed over time
They must:
Share results with relevant managers: so findings are acted on
Take corrective action: to fix problems and prevent them happening again
Clause 9.3: Management review
Senior leaders must regularly review:
Design for All policy and goals: as set out in clauses 5.2 and 6.2
Performance and audit results: including findings from evaluations and internal audits (clauses 9.1 and 9.2)
These reviews should cover:
Progress on previous actions: tracking follow-up and results
Relevant changes: both internal and external
Effectiveness of the approach: how well Design for All is being applied
Trends and indicators, such as:
Accessibility outcomes
User feedback
Supplier performance
Internal audit findings
Opportunities for improvement: and how well risks and opportunities have been addressed
The review must lead to clear decisions and actions to improve accessibility and extend the range of users. Leadership is also responsible for ensuring the organisation has the resources needed to carry out these improvements.
Clause 10: Improvement
Organisations must treat accessibility as an ongoing effort. That means acting on feedback, checking progress, and always looking for better ways to meet users' needs. Improvements should be based on evidence and regularly checked for impact.
This means they must:
Identify areas to improve: across processes, procedures, and activities
Take action: to make those improvements
Check the results: to see if the changes worked as expected
Improvements should be guided by:
Management review outcomes: outlined in clause 9.3
Accessibility goals and objectives: outlined in clause 6.2
Performance evaluations: outlined in clause 9.1
Internal audit results: outlined in clause 9.2
Data analysis: that highlights problems or opportunities
As well as evaluating its performance against the Design for All approach (Clasue 9.2), organisations can also carry out assessment of products and services in order monitor progress and improvements.
