EN 301 549 Section 11.7 Offers Challenges for Accessibility Teams

Accessibility can become unnecessarily complicated at times. Those working in the field can get mired down in complex interpretation of requirements which, in fairness, can be vague. In the midst of discussing and deliberating on the topic, it’s easy to lose focus on what matters most – what will best serve the user.  

In this blog, I examine one small bit of accessibility complexity in part of the EN 301 549 standard, part of the European Accessibility Act. I use section 11.7 User Preferences as an example to illustrate how organizations may become easily confused on what to do in certain accessibility scenarios.

What is 11.7 User Preferences?

A requirement in EN 301 549 – found here under 11.7 User Preferences. It currently has the following language:

Where software is not designed to be isolated from its platform, and provides a user interface, that user interface shall follow the values of the user preferences for platform settings for: units of measurement, colour, contrast, font type, font size, and focus cursor except where they are overridden by the user.

NOTE 1: Software that is isolated from its underlying platform has no access to user settings in the platform and thus cannot adhere to them.

NOTE 2: For web content, the underlying platform is the user agent.

NOTE 3: This does not preclude the software from having additional values for a setting as long as there is one mode where the application will follow the system settings even if more restricted.

11.7 User Preferences is currently applicable to websites, and as a result, should be tested given the current language in EN 301 549. However, the language of 11.7 will change in an upcoming release to exclude websites from its scope.

What does 11.7 User Preferences apply to?

Due to the current wording, it is interpreted that 11.7 applies to:

• desktop applications,
• mobile applications,
• websites

In addition, 11.7 is listed as “Unconditional” for web content in Table A1 of EN 301 549 (see page 95 for its listing).

How does 11.7 User Preferences apply to websites?

Web browsers have settings that allow users to change things like font, type size, color, background color, and more. Websites should reflect these changes so users can read sites according to their personal preferences, not just as the website author presents the content. For example:

Default display from the Applause website:

User preferences changing text size, font, text color, and background color:

How is this currently tested on websites?

One of the ways to test 11.7 User Preferences is to use the Firefox browser. Testers change the settings for font, font size, text color, and background color then verify that the website responds to these changes and is legible. The German BIK test firm gives a detailed methodology. It’s also possible to test in Chrome using some flags, but testing in Firefox is most robust.

What about dark mode / dark themes?

In its current form, some have interpreted 11.7 as requiring the website to support a dark mode. For example, Digg in Sweden specifically notes that a website should display in a dark theme if the user has selected it on their computer in system settings. Digg notes that limitations exist  that could prevent displays from meeting this requirement in some instances.

What is the latest update on 11.7 User Preferences for websites?

ETSI Labs currently has a multi-year discussion underway about 11.7 and its applicability to mobile applications and websites. After lots of back and forth, and a flurry of activity in the last few months, a decision was made in January to update the language of 11.7 to remove websites from its scope. The updated language is likely to be as follows:

11.7 User Preferences

Where ICT is or includes non-web software that provides a user interface, and is not designed to be isolated from its platform,

that user interface shall follow the values of the preferences that users have set for the platform documented accessibility features.

NOTE 1: Software that is isolated from its underlying platform has no access to user settings in the platform and thus cannot adhere to them.

NOTE 2: This does not preclude the software from having additional values for a setting as long as there is one mode where the application will follow the system settings even if more restricted.

NOTE 3: Platform documented accessibility features of the user interfaces usually include colour, contrast, font type, font size, and space adjustments for characters, lines and paragraphs.

With the above change, 11.7 will apply to desktop applications and mobile applications, but not websites.

What should we do now regarding testing 11.7 on our website?

While it can take time to finalize an update like this and publication schedules often shift, many people involved in this discussion believe it will likely happen by the end of 2026. This leaves teams in a position of having to test websites for 11.7 according to the current language. As we test EN 301 549 in its current form, we must decide how to handle both the reporting and remediation of the issues. Some options are:

• Continue to test 11.7 against web, file bugs noting the failure of 11.7, and provide recommendations on how to fix the issues, or
• Remove web testing from 11.7 entirely, with a view to waiting on the standard to be updated

Given the potential legal issues inherent in the European Accessibility Act, Applause recommends continuing to test 11.7 against web per current language in EN 301 549, but, perhaps, with a lower priority given that it will be removed in a future update. Applause plans to keep clients current on the upcoming update to 11.7. 

Supporting user preferences on a website is a good thing – along with a general robust and evolving accessibility program –  regardless of legal obligations, so clients can decide on an individual basis where these 11.7-related bugs fit into their roadmap.

Insights from around the world make a difference

Your organization may not have much experience in accessibility, or perhaps you are rather advanced in your knowledge of accessibility. Either way, Applause can help. We have over a decade of deep accessibility experience and draw from working with a wide range of client accessibility scenarios, awareness and competency levels. This direct insight into global accessibility issues and inclusive design enables us to offer a unique perspective to help global firms no matter where they are in their accessibility journey. 

Find out more about Applause accessibility testing.