A product can be fully compliant with EN 301 549 and still be unusable.
This isn't controversial among people who actually do accessibility work. It is often a surprise to the people paying for it.
Compliance exists to set a legal floor. A checklist-able one, ideally automatable. That's useful. It's also not the same thing as accessibility, and the distinction matters.
What compliance measures
EN 301 549 references WCAG 2.1 AA. WCAG measures component-level behavior. Can a screen reader find the button. Does the contrast ratio meet 4.5:1. Is the focus indicator visible. Is the page operable with a keyboard alone.
These are real questions. Getting every one of them right, on every page, across a product, is non-trivial.
But each check is local. You can tick every box and still ship a product nobody disabled can actually use.
What it doesn't measure
The thing WCAG can't check is whether a person can accomplish the task they came to do.
- A form that passes every WCAG criterion but is forty fields long with no saving between sessions.
- A login flow that works with NVDA but has a thirty-second timeout before the TOTP code becomes unreachable.
- A data table where every cell is correctly labeled but there are two thousand rows and no way to filter.
- A "skip to main content" link that is present and focusable but lands on a wrapper that isn't, so the skip does nothing.
Each is compliant at the component level. Each is inaccessible at the task level.
The gap has a name
WCAG measures perceivability, operability, understandability, robustness. It does not measure cognitive load, attention cost, time pressure, or task completion.
A real user has finite working memory. Real browsers have quirks. Real assistive tech has bugs. Real motor conditions mean interactions take longer. Compliance treats all of that as outside scope.
A product that doesn't think about them will pass an audit and still exclude people.
Why compliance becomes a ceiling
Organizations that treat compliance as the goal stop improving once they pass.
The pattern: an audit is booked, issues are filed, tickets are closed, the report says AA. No one tests with an actual screen reader user. No one watches someone with ADHD try to complete the checkout. The accessibility program now exists to maintain the score, not to make the product usable.
The name for this is checkbox compliance. The cost is that the product can deteriorate on every axis WCAG doesn't watch, and the score stays green.
The real bar
Accessible means a person using assistive technology can accomplish the task in roughly the same time and with roughly the same cognitive cost as someone without it.
Roughly. Not identical. Not "they can at least get there eventually if they try hard enough." Roughly the same.
That is a much higher standard than WCAG AA. It is also the actual bar. Passing an audit is the start of the work, not the end of it.