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ADA, Section 508, the EAA and EN 301 549: What Is the Difference?

By Rohit, DHS Trusted Tester (Section 508) · Updated October 1, 2026

Four acronyms, two continents, one underlying standard. Here is how the main US and EU accessibility rules fit together, and which ones apply to you.

The short answer

WCAG is the set of technical guidelines. The ADA and Section 508 are US laws, and the European Accessibility Act (EAA) is an EU law. EN 301 549 is the European standard that gives the EAA its technical detail. Almost all of them lean on WCAG, which is why one careful audit can serve both markets.

Who is who

WCAG

The Web Content Accessibility Guidelines are published by the W3C. Version 2.2 is the newest, and Level AA is the level most laws and contracts ask for. WCAG is not a law itself.

ADA (United States)

The Americans with Disabilities Act is a civil rights law. Title III covers businesses open to the public, which courts have applied to websites, and Title II covers state and local governments. Title III doesn't name a technical standard, so WCAG is what settlements and courts usually use. For Title II, the Department of Justice rule points to WCAG 2.1 AA, with deadlines in April 2027 and April 2028.

Section 508 (United States)

Section 508 covers federal agencies and the vendors who sell to them. It points to WCAG 2.0 AA, and buyers usually ask for a VPAT or ACR as proof. The DHS Trusted Tester certification is a method for testing against it.

European Accessibility Act (European Union)

The EAA has applied since 28 June 2025. It covers consumer services including e-commerce, banking, e-books and booking transport, and it applies to businesses outside the EU that sell to EU consumers. Microenterprises that provide services are exempt. Each EU country has its own law and its own penalties.

EN 301 549 (European Union)

EN 301 549 is the European standard for ICT accessibility. For web content, version 3.2.1 is based on WCAG 2.1 AA and currently gives a presumption of conformity. Version 4.1.1, published in September 2026, is based on WCAG 2.2 AA and will take over once the European Commission cites it. The EU's Web Accessibility Directive, which covers public sector websites and apps, uses the same standard.

How they compare

The practical differences

• Enforcement. In the US, most pressure comes from private lawsuits and demand letters. In the EU, national authorities enforce the rules, penalties differ by country, and disability organizations have also started legal action.
• The named standard. The EU names EN 301 549. US law for private businesses doesn't name one, so WCAG fills the gap.
• Who is covered. The ADA covers businesses open to the public. The EAA covers specific consumer services, with an exemption for the smallest providers.
• Paperwork. US buyers ask for a VPAT or ACR. The EU expects accessibility information for consumers, and VPAT templates also exist in an EN 301 549 edition.

Which one applies to you?

• You sell to consumers in the US: the ADA is your main risk.
• You sell to consumers in the EU, even from outside it: the EAA and EN 301 549 apply, unless you are a microenterprise providing services.
• You sell software to US government agencies: Section 508 and a VPAT.
• You sell to public bodies in Europe: the Web Accessibility Directive and EN 301 549, usually through tender requirements.
• You sell in both: all of the above can apply to the same website.

Can one audit cover both?

Yes. The technical work is the same: testing by hand with a keyboard and screen readers against WCAG 2.2 AA. What changes is how the findings are mapped and reported. For the EU, I map each finding to its EN 301 549 clause (web content is clause 9) as well as its WCAG criterion. For the US, I reference the ADA, Section 508 and WCAG.

See the EU audit page, the US lawsuit data, or compare the rules side by side.

This article is general information, not legal advice. For questions about your legal obligations or a claim you have received, talk to an attorney.