Research · European rules

The European rules for digital public services

This document summarises the European rules for digital public services: accessibility, ease of use (usability) and design systems (shared rules and reusable building blocks for websites and apps). It reflects the situation on 19 October 2026. Here you will find the legal acts, the standards, the deadlines and what a government design system should offer in order to comply with them.

Note. I checked the articles in the full texts and on the official pages of the Commission, of ETSI (the European Telecommunications Standards Institute) and of the W3C (the consortium that publishes WCAG). The country-by-country catalogue: Design systems in Europe.

0. In brief

1. There is no European law on ease of use, but accessibility is mandatory. Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies (the Web Accessibility Directive, WAD) covers public institutions. Directive (EU) 2019/882 on the accessibility requirements for products and services (the European Accessibility Act, EAA) has applied since 28 June 2025 to products and services, including those offered by public institutions.
2. The technical basis is the standard EN 301 549 V3.2.1, that is, WCAG 2.1 AA (WCAG: the international web accessibility guidelines). Version V4.1.1 (2 September 2026) moves to WCAG 2.2 AA. It is not yet cited in the Official Journal of the EU (checked on 21 October 2026). Specialist sources expect the citation between the end of November and mid-December 2026. There is no official date. My recommendation: design directly to WCAG 2.2 AA.
3. Ease of use is regulated piecemeal: Regulation (EU) 2018/1724 establishing a single digital gateway (SDG), Regulation (EU) 2024/903 laying down measures for a high level of public sector interoperability across the Union (the Interoperable Europe Act), Regulation (EU) 2024/1183 amending Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework (eIDAS 2.0), Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (the Artificial Intelligence Act, AI Act), the General Data Protection Regulation (EU) 2016/679 (GDPR), Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector (the ePrivacy Directive) and political declarations.
4. The EU does not require member states to have a design system. More than 20 European countries have one; Romania does not. Portugal, Slovakia, the Republic of Moldova and Switzerland make it mandatory; Germany gives it formal funding from 2027, and France reserves it for state websites.
5. Useful process standards: ISO 9241-210, EN 17161, ISO 24495 (plain language), the 2022 principles of the Organisation for Economic Co-operation and Development (OECD) and the UK Service Standard.
6. Romania has accessibility legislation and monitoring by the Romanian Authority for Digitalisation (ADR), but neither a design system nor a service standard. Bill PL-x 300/2026 was submitted in February 2026, and in June 2026 ADR started a project on user-centred services. In the 2025 OECD Digital Government Index, Romania had the lowest score of the 42 countries assessed (0.24).

A1. The Web Accessibility Directive (WAD), Directive (EU) 2016/2102

It applies to the websites and apps of public sector bodies, including intranets and extranets. Content must be perceivable, operable, understandable and robust (Art. 4). The content exceptions (Art. 1(4)) include office documents published before 23 September 2018, audio-visual recordings published before 23 September 2020, live broadcasts, maps, third-party content and archives. Disproportionate burden (Art. 5) can be invoked only after an assessment and with alternatives.

Deadlines: new websites by 23 September 2019, all websites by 23 September 2020, apps by 23 June 2021.

Obligations (Art. 7): an accessibility statement, a feedback mechanism and a link to the enforcement procedure. Monitoring is annual (Commission Implementing Decision (EU) 2018/1524). Auditors first check the home page, sign-in, the contact page, one page per service, the statement and the feedback page. These are the templates that a design system would solve first.

The next national reports are expected around December 2027. As of October 2026 I had not found a proposal to revise the directive; I am still following the subject. The Commission says that accessibility overlays are not an acceptable solution.

A2. The European Accessibility Act (EAA), Directive (EU) 2019/882

It has applied since 28 June 2025. It covers products (computers, self-service terminals, e-readers) and services (electronic communications, passenger transport, banking, e-books, e-commerce, and 112 emergency calls from 28 June 2027). Microenterprises providing services are exempt. The transition lasts until 2030, and until 2045 for terminals. The provider explains in its terms and conditions how it meets the requirements (Annex V). In public procurement, the EAA requirements are mandatory (Art. 24).

Institutions' websites remain under the WAD, but the EAA applies to the services it covers regardless of who provides them, for example an institution that sells tickets online (my interpretation, not yet confirmed by a lawyer).

A3. The harmonised standard EN 301 549

V4.1.1 adds the six new criteria from WCAG 2.2, removes criterion 4.1.1 and strengthens the requirements on user preferences. It does not bring a new deadline. Clause 10 covers documents (PDF, Office).

A4. The WCAG versions

WCAG 2.1 AA is today's legal level, through EN 301 549. WCAG 2.2 (W3C, 2023; ISO/IEC 40500:2025) becomes the legal reference once V4.1.1 is cited in the Official Journal. WCAG 3.0 is only a draft (September 2026) and is not used for conformance.

A5. The accessibility statement: mandatory content (Decision 2018/1523)

The model is set by Commission Implementing Decision (EU) 2018/1523. The statement includes: the institution and the scope covered; the compliance status (fully, partially or not compliant); inaccessible content, with alternatives; the date and method of the assessment, with a review at least once a year; the feedback mechanism; the link to the enforcement procedure. A design system would offer a configurable statement template and a standard link in the footer.

A6. National transpositions (a selection)

• Germany also requires explanations in sign language and in easy-to-read language. Spain has a new rule on cognitive accessibility (Royal Decree, RD, 707/2026).
• France (RGAA, the French accessibility reference framework; version 5 planned for the end of 2026) imposes fines of up to €50,000. Italy requires the statement every year, by 23 September.
• Romania: Government Emergency Ordinance (OUG) 112/2018 on the accessibility of websites and mobile applications of public sector bodies (approved by Law 90/2019) refers to EN 301 549 „și versiunile ulterioare” (“and subsequent versions”). ADR does the monitoring (reports for 2021–2025). The EAA is transposed by Law 232/2022 on the accessibility requirements for products and services, applicable from 28 June 2025, with enforcement shared between the National Authority for Consumer Protection (ANPC), the National Authority for Management and Regulation in Communications (ANCOM), ADR, the National Audiovisual Council (CNA) and others, and fines of about 5,000–15,000 lei per offence.

A7. What the monitoring finds

• Austria (2022–2024): the most frequent errors concern alternative text, structure, contrast, keyboard use, focus and criterion 4.1.2 (name, role, value). Only about half of the websites had a statement.
• Ireland (2024): criterion 4.1.2 accounted for 45% of errors; 67% of websites and all apps had no statement.
• France: in March 2026, about 6.5% of the 250 essential services were fully compliant, against the target of 100% for December 2025.

The priorities of a design system, by frequency of errors: correct name, role and state (4.1.2); semantic structure; default contrast (4.5:1 for text, 3:1 for the interface); visible focus; keyboard access; templates for the statement and for feedback.

B1. Political declarations (not binding, but fundamental)

• Tallinn Declaration (2017): user-centred principles, digital by default and “once-only” (data is given to the state only once).
• Berlin Declaration (2020): digital inclusion, trust, human-centred systems.
• Lisbon Declaration (2021): digital transformation seen through human rights.
• European Declaration on Digital Rights and Principles (2022): online access for everyone, data not requested more often than necessary, offline alternatives kept.

B2. The Single Digital Gateway Regulation (EU) 2018/1724, “Your Europe”

It contains the most concrete European rules on the ease of use of public services.

• Art. 9, quality of information. Information must be user-friendly and easy to find, accurate, complete, well structured and kept up to date. It must show the responsible authority, contact details, the relevant legal acts and the date of the last update. It is written in “clear and plain” language, adapted to users, and in an EU language that is widely understood.
• Art. 10, information about the procedure before identification. In practice, a mandatory “Before you start” page, with: the steps; the authority; the accepted means of electronic identification and signature; the evidence required and its format; the means of redress; fees and payment; deadlines or the estimated duration; what happens if no reply comes (tacit approval); the languages available. The user is notified when there are delays.
• Art. 13, access from another state: forms accept addresses, names and documents in foreign formats; eIDAS authentication, electronic evidence and results, cross-border payments.
• Art. 14, the “once-only” system: only at the user's explicit request, with a preview of the evidence and with an alternative available.
• Art. 17: non-compliant services can be disconnected from the gateway.
• Art. 18: a common user interface, easy to use on any device, accessible.
• Art. 22: the “Your Europe” logo is a quality label for Art. 9–11.
• Art. 25: anonymous feedback immediately after using the service, from any page (details in Commission Implementing Regulation (EU) 2020/1121).

B3. The Interoperable Europe Act (EU) 2024/903 and the European Interoperability Framework

The regulation has applied since July 2024, with mandatory interoperability assessments from January 2025. Solutions are shared and reused, preferably under open licences. The German KERN system appears in the European catalogue of open-source software. The relevant principles of the European Interoperability Framework (EIF, 2017): user-centricity (P6), inclusion and accessibility (P7), multilingualism at every level (P9), digital by default (P10). A revised EIF is expected in 2027.

B4. The Digital Decade 2030 and the eGovernment Benchmark

Decision (EU) 2022/2481 establishing the Digital Decade Policy Programme 2030 requires 100% of key public services to be online. The Digital Decade Board recommends measuring actual use, not only availability.

eGovernment Benchmark 2026 (96 services, more than 14,000 websites): services for citizens 84.6; pre-filled forms 75.6; transparency 69.6 (the lowest of the core areas); support 90.0; mobile 97.4; chatbots 39.5. Fewer than 1 in 4 government websites uses a recognisable government domain, which affects trust and protection against fraud. Conclusion: transparency patterns (progress, duration, application status) have the most room for growth; mobile friendliness is largely solved.

B5. The Commission's design and web guidelines

The Europa Component Library (ECL) v5.3.2 (8 October 2026) is the Commission's design system. The Europa Web Guide requires user research and WCAG 2.1 AA. The web writing guidelines recommend sentences of no more than about 25 words, one idea per sentence, with no jargon. The brochure “How to write clearly” has 10 tips, in all EU languages. For EU Login I found no public user experience guidelines.

B6. The European Digital Identity Wallet, eIDAS 2.0 (Regulation (EU) 2024/1183)

Its requirements work as user experience rules for any government sign-in: selective disclosure (only the data needed), the transaction history, the request to delete data, free of charge, voluntary use, with no disadvantage for those who do not use it, accessibility. Commission Implementing Regulation (EU) 2026/1731 requires the trust mark and explicit confirmation before the facial photograph is sent (details from secondary sources).

Deadlines: each state provides a wallet by 24 December 2026; regulated private sectors accept it by 24 December 2027. The Commission has not published user experience guidelines for the wallet.

B7. The OECD frameworks

The OECD Good Practice Principles for Public Service Design and Delivery in the Digital Age (2022), drawn from the standards of 14 governments, have three pillars: users' needs before those of the administration; delivery with impact, at scale (principle 6: design systems and shared components); accountability and transparency. The OECD Digital Government Policy Framework (2020) underpins the Digital Government Index, where Romania scored 0.24 in 2025, the lowest score of the 42 countries assessed.

B8. Usability and design standards

B9. Artificial intelligence, personal data and deceptive interface patterns

• The AI Act, Art. 50 (from 2 August 2026): a chatbot tells users that they are talking to an AI, at the latest at the first interaction. A design system would need an “AI assistant” notice component.
• GDPR: information in plain language (Art. 12), data protection by design (Art. 25). ePrivacy: non-essential cookies require consent.
• The European Data Protection Board (EDPB): Guidelines 03/2022 classify deceptive design patterns. The lack of a “Reject” button on the first layer of the cookie banner is considered problematic.
• Regulation (EU) 2022/2065 on a Single Market for Digital Services (the Digital Services Act, Art. 25) bans deceptive patterns on platforms; for government portals it is a reference point, not an obligation. The Digital Omnibus and the Digital Fairness Act had not been adopted as of October 2026.

C1. Is there an EU design system?

For the EU institutions, yes: ECL (EUPL licence) and eUI (internal applications). For member states, no. The EU offers shared principles (EIF, SDG), shared standards (EN 301 549) and shared infrastructure (the Interoperable Europe portal, the once-only system, the identity wallet). The Interoperable Europe Act encourages the reuse of open-source solutions, which is why many national systems use the EUPL licence.

C2. National service standards (“the rules above the design system”)

About the bill: Analysis of the bill and The bill's legislative journey.

C3. The landscape of national design systems

The details are in the Design systems in Europe.

• Mature and open: the United Kingdom, the Netherlands, Italy, Norway, Germany, Finland, Denmark, Estonia and others.
• Mature, but restricted: France, Flanders, Spain, Portugal, Greece.
• Recent: Czechia, Hungary, the Republic of Moldova.
• No national system (October 2026): Romania, Bulgaria, Croatia, Slovenia, Malta, Latvia, Lithuania. Only part of one: Belgium (only Flanders), Austria (at federal level, only a visual identity), Luxembourg (only a common framework for content), Sweden (only the systems of some agencies).

The current trend: a core of web components, with adapters for different frameworks.

In brief, by topic

What a European government design system should offer:

• Accessibility: components at WCAG 2.2 AA; templates for the statement, feedback and documents; room for easy-to-read language and sign language; no accessibility overlays.
• Ease of use: the “Before you start” page; the authority and the date of the update on every page; anonymous feedback; application tracking; pre-filled data with a preview; foreign formats; multilingualism; an offline channel.
• Identity and trust: sign-in with the European wallet; a clear official website pattern.
• AI and personal data: information about AI; “Reject” on the first layer of the cookie banner; a list of deceptive patterns to avoid.
• Content: a plain language guide (ISO 24495).
• Governance: ISO 9241-210 and EN 17161; the EUPL-1.2 licence; tests with people with disabilities; a service standard above the system.

Timeline

What I am following next

1. The citation of EN 301 549 V4.1.1 in the Official Journal.
2. The publication of RGAA 5 in France.
3. A possible revision of the WAD.
4. The details of Commission Implementing Regulation (EU) 2026/1731.
5. The Digital Omnibus and the Digital Fairness Act, not yet finalised.
6. PL-x 300/2026: adopted by the Senate (96–1, 1 April 2026), in the committees of the Chamber of Deputies, with no report (the deadline for the report was 5 May 2026).
7. The exact wording of the articles of the EAA, the SDG, the Interoperable Europe Act and eIDAS 2.0, before any legal citation.

Sources

EU legislation and policy

• Directive (EU) 2016/2102
• The Commission's page on web accessibility
• Commission Implementing Decision (EU) 2018/1523
• Commission Implementing Decision (EU) 2018/1524
• WAD monitoring reports 2022–2024
• Study supporting the review of the WAD
• National transposition measures for Directive 2016/2102
• Directive (EU) 2019/882
• The Commission's page on the EAA
• Regulation (EU) 2018/1724
• Commission Implementing Regulation (EU) 2020/1121
• The Interoperable Europe Act
• The EIF principles
• The Declaration on Digital Rights and Principles
• The Tallinn Declaration
• The Berlin Declaration
• eGovernment Benchmark 2026
• The European identity wallet, technical standards
• The European identity wallet, architecture and reference framework
• EDPB Guidelines 03/2022

Standards

• EN 301 549 V3.2.1
• EN 301 549 V4.1.1
• AccessibleEU on V4.1.1
• WCAG 2.2 · WCAG 3.0 (draft)
• EN 17161
• ISO 9241-210 · ISO 9241-110 · ISO 24495-2

European Commission: design and content

• ECL
• Europa Web Guide
• Web writing guidelines

OECD

• Good Practice Principles (2022)
• The Digital Government Policy Framework

National sources

• United Kingdom, Service Standard
• Germany: https://servicestandard.gov.de · https://www.gesetze-im-internet.de/ozsv/__2.html · https://www.kern-ux.de/
• France: https://www.systeme-de-design.gouv.fr · https://observatoire.numerique.gouv.fr
• Italy: https://www.agid.gov.it/sites/default/files/repository_files/design-linee-guida-docs.pdf · https://designers.italia.it
• Netherlands: https://nldesignsystem.nl · https://www.digitoegankelijk.nl/nieuws/modeltoegankelijkheidsverklaring-vastgesteld
• Sweden, DIGG
• Ireland, NDA
• Austria, 2024 monitoring report

Romania

• OUG 112/2018
• Law 232/2022
• ADR, accessibility of websites
• OSOR country factsheet for Romania (2025)

← All research documents