On 2 September 2026 ETSI, CEN and CENELEC published EN 301 549 V4.1.1, the first new edition of Europe’s accessibility standard for ICT since V3.2.1 in 2021. The three organisations formally adopted it on 24 August. It is the standard the European Commission asked for in Standardisation Request M/587 back in 2022, and it is meant to become the harmonised standard behind the European Accessibility Act (EAA).

Here is what changed, what has not changed yet, and what to do about it.

WCAG 2.2 replaces WCAG 2.1

V3.2.1 built its web, document and software clauses on WCAG 2.1 Level A and AA. V4.1.1 moves the baseline to WCAG 2.2. Clause 9 (web content) now carries every WCAG 2.2 Level A and AA success criterion, and clauses 10 (non-web documents) and 11 (non-web software, which includes mobile apps) are updated to match, with the usual adaptations for content that is not a web page.

Compared with the WCAG 2.1 baseline, six success criteria are new:

  • 2.4.11 Focus Not Obscured (Minimum)
  • 2.5.7 Dragging Movements
  • 2.5.8 Target Size (Minimum)
  • 3.2.6 Consistent Help
  • 3.3.7 Redundant Entry
  • 3.3.8 Accessible Authentication (Minimum)

One criterion has gone. WCAG 2.2 removed 4.1.1 Parsing, so clause 9.4.1.1 in the new edition is marked void. If your test plan still has a parsing check, you can retire it.

New annexes map the standard to the EAA

The most important structural change is Annex ZB, which maps the standard’s requirements to the accessibility requirements in Annex I of the EAA. Annex ZA does the same job for the Web Accessibility Directive, which covers public sector websites and apps. A new clause A.2 supports assessing a specific product or service category against the EAA requirements that apply to it.

Until now, anyone trying to show that a service met the EAA had to build that mapping themselves. The new annexes give everybody the same starting point.

Elsewhere, the real-time text requirements in clause 6.2 are substantially revised, including concurrent voice and text, clause 6.7 extends towards “total conversation” combining text, voice and video, and the user preference requirements are reworked so they read consistently across web, documents and software.

What has not changed yet

Publication by the standards bodies is not the same as citation in the Official Journal of the European Union. Until the Commission cites V4.1.1 in the Official Journal, conforming to it does not give a presumption of conformity with the EAA. For the Web Accessibility Directive, the Commission’s implementing decision still cites V3.2.1, and that does not change until the decision is updated.

ETSI’s own planning documents gave a provisional target of 30 November 2026 for citation. Treat that as a planning date rather than a deadline. The EAA itself has applied since 28 June 2025 regardless. The standard is the easiest route to showing conformity, not the obligation itself.

What to do now

  1. Record what applies to you today. Note the laws, contracts and standard editions you are currently held to, then treat V4.1.1 as the readiness target.
  2. Close the WCAG 2.2 gap. If your last audit was against WCAG 2.1, test the six new criteria. Target size and accessible authentication catch out a lot of otherwise careful teams, and dragging movements matters for any touch interface.
  3. Do not relabel. A WCAG 2.1 audit report is not evidence against V4.1.1, and WCAG 2.2 AA conformance is not the same as full EN 301 549 conformance. The standard has clauses for hardware, documents, authoring tools, support services and more.
  4. Ask suppliers which edition their evidence covers. Accessibility conformance reports should name the edition and the clauses tested.
  5. Update your statement. If your accessibility statement names EN 301 549 V3.2.1, plan the wording change for when citation happens.

The published text is on ETSI’s delivery server. Davis Wright Tremaine has a useful legal summary, and Pivotal Accessibility published a clause-level walkthrough.

Try it this week

Run an Audit in Accessibility Checker on one key page and look for target-size findings among the results, since 2.5.8 is one of the new WCAG 2.2 criteria. Then read the lesson How EN 301 549 works for the structure of the standard, and Clause 9: web for how the WCAG criteria are incorporated.

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