User preferences in EN 301 549 V4.1.1 (9.7, 10.7, 11.7)
Clauses 9.7, 10.7 and 11.7 of EN 301 549 V4.1.1 require websites, documents and software to respect user accessibility settings instead of overriding or blocking them. Exceptions apply when overriding is essential for content or function. This requirement is not in WCAG 2.2, so a classic WCAG audit will not cover it.
What the standard requires
Many people use operating system or browser settings that adapt the screen to their needs. Someone with low vision increases system text size, a person sensitive to light enables high contrast mode, someone with colour vision deficiency uses colour filters. Those settings work only when the site or app does not ignore them.
The new sub-clauses of the standard cover three domains:
- 9.7 applies to websites and browser or platform settings,
- 10.7 applies to documents and document reader settings,
- 11.7 applies to software, including mobile apps.
In V3.2.1 only software (11.7) had this requirement. What is new is extending the rule to websites and documents.
Which settings are covered
The standard lists among others colour filters, contrast, text size, pointer size, and text cursor. In practice, after changing these settings in the system, the site or app should adapt rather than look exactly the same.
When overriding is allowed
The requirement does not ban a custom look. It allows overriding user settings when that is essential for content or function. Examples: a photo editing tool that must show true colours, or a game where element size is part of gameplay. A logo in corporate colours or “consistent brand look” is not justification for the entire interface.
How to test on different systems
Testing means changing settings and observing the response. Menu names differ between system versions, so below we give settings, not exact paths.
| System | What we change | What we check |
|---|---|---|
| Windows | Text size, contrast themes, colour filters, pointer size and colour, text cursor indicator | Whether text grows and is not clipped, whether the site respects contrast mode, whether the cursor stays visible |
| macOS | Increased contrast, colour filters, pointer size | Whether the interface stays readable and does not block changes |
| iOS | Larger text (Dynamic Type), increased contrast, colour filters | Whether the app scales text and layout, whether nothing disappears from the screen |
| Android | Font and display size, high-contrast text, colour correction | Whether in-app text grows with the system, whether layout does not break |
| Browser | Minimum font size, forced colours mode | Whether the site does not block font changes and works correctly in forced colours |
Typical failures
We most often see three groups of problems:
- Fixed text sizes in apps. Text set in pixels instead of units scaled by the system (e.g. sp on Android, Dynamic Type on iOS) does not grow when settings change.
- Blocking contrast mode. Styles that force custom colours even in high contrast mode, or backgrounds and icons that vanish in forced colours mode.
- Custom cursors and pointers. Replacing the system cursor with a custom one that ignores set size or colour.
For web developers, CSS media queries such as forced-colors and prefers-contrast, and relative units for text, are helpful.
Web views in apps
The standard also resolves a common doubt: a web view embedded in a mobile app is assessed under clause 11 (software), not 9. Both clauses do not apply at once. For user preferences, such a view should react to system settings like the rest of the app.
Have a mobile app or a large site? Order testing on real devices as part of Accessibility PREMIUM.
Frequently asked questions
Is a WCAG 2.2 audit enough for EN 301 549 conformity?
No. The standard includes requirements outside WCAG, including 9.7, 10.7, and 11.7, and requirements for documentation, communication, and hardware. See also the overview of V4.1.1 changes.
How do I check whether an app respects large text?
Set the largest text size in the system, open the app, and check whether text grows, is not clipped, and all functions remain available.
Sources
- ETSI EN 301 549 V4.1.1 (2026-09)
- BarrierBreak: EN 301 549 V4.1.1
- Deque: EN 301 549 V4.1.1 is final