EN 301 549 V4.1.1 and WCAG 2.2: what changes for your website

Reviewed 30 September 2026. General information, not legal advice.

Short answer: EN 301 549 is the European standard for the accessibility of digital products and services. Version 4.1.1 was published in September 2026. For websites its main change is the move from WCAG 2.1 to WCAG 2.2 at levels A and AA, which adds six success criteria. Only one of the six, target size, can be checked automatically; the other five need a person.

What EN 301 549 is, and what V4.1.1 changes

EN 301 549, “Accessibility requirements for ICT products and services”, is published jointly by ETSI, CEN and CENELEC. It is the standard the European Commission asked for to support the European Accessibility Act, and the version dated September 2026 is V4.1.1. Its clause 9 covers web content, and it does so by adopting the W3C’s Web Content Accessibility Guidelines.

The previous version, V3.2.1, adopted WCAG 2.1. V4.1.1 adopts WCAG 2.2 at levels A and AA. It also revises the requirements on user preferences and on real-time text communication, and adds annexes that map its clauses to the requirements of the European Accessibility Act. For a typical website or shop, the WCAG 2.2 criteria are the part that matters.

The six new success criteria

WCAG 2.2 success criteria at levels A and AA that were not in WCAG 2.1
Success criterion	Level	What it asks for	Automated test?
2.4.11 Focus Not Obscured (Minimum)	AA	The element that has keyboard focus is not completely hidden by something the page puts on top of it, such as a sticky header, a cookie banner or a chat widget.	No
2.5.7 Dragging Movements	AA	Anything done by dragging — a slider, a sortable list, a map — can also be done with single clicks or taps.	No
2.5.8 Target Size (Minimum)	AA	Buttons and links are at least 24 by 24 CSS pixels, or have enough space around them. Links inside a sentence are exempt.	Yes, largely
3.2.6 Consistent Help	A	Help that appears on several pages — contact details, a chat, a help link — sits in the same place relative to the rest of the page each time.	No
3.3.7 Redundant Entry	A	Information a customer has already entered in a process is filled in or offered for selection, not asked for again. The classic case: the billing address after the delivery address.	No
3.3.8 Accessible Authentication (Minimum)	AA	Logging in does not depend on a memory or puzzle test without an alternative. Password managers and pasting must work; a CAPTCHA that needs transcription needs another route.	No

WCAG 2.2 also removes one criterion: 4.1.1 Parsing is obsolete. The W3C explains each new criterion in “What’s New in WCAG 2.2”.

How to test the five that a scanner cannot

Focus not obscured. Press Tab through each page type with the cookie banner open and again after scrolling. If the focused link disappears behind a sticky header or footer, it fails.
Dragging. List every control operated by dragging: price sliders, image carousels, drag-and-drop uploads, maps. Each needs a click alternative, such as plus and minus buttons or an input field.
Consistent help. Compare the position of your contact and help links on the home page, a product page and the checkout.
Redundant entry. Go through checkout and registration once. Note every piece of information you are asked for twice.
Accessible authentication. Log in with a password manager. Check that pasting into the password and one-time-code fields is not blocked, and that any CAPTCHA has an alternative that is not a puzzle.

What it means legally

A harmonised standard gives a “presumption of conformity” with the law once its reference has been published in the Official Journal of the European Union. For V4.1.1 that step was still outstanding when this guide was reviewed, and is expected around the end of 2026. Until then the standard is published but does not yet carry the presumption.

Two things are worth knowing in the meantime. Article 13(3) of the European Accessibility Act already requires service providers to take changes in harmonised standards into account. And conforming to WCAG 2.2 also satisfies WCAG 2.1, so working to 2.2 now costs nothing in terms of the old benchmark. Whether and from when V4.1.1 is binding for your service in a given country is a question for a lawyer.

Meeting WCAG 2.2 AA is also not the same as meeting all of EN 301 549: the standard contains further requirements, for example for documents, software and support services.

What to do now

Test against WCAG 2.2, not 2.1. Check that your scanner or auditor actually runs the 2.2 rules; some tools still stop at 2.1.
Walk through the five manual checks above on your main templates and your checkout.
Fix small touch targets in shared components first — icon buttons, pagination, footer links — because one fix applies everywhere.
Update the standard named in your accessibility statement once you have tested against it.

RampCheck runs the WCAG 2.0, 2.1 and 2.2 rules of axe-core at levels A and AA, including the target size check. It does not test the other five criteria, because no automated tool reliably can.

Questions

When was EN 301 549 V4.1.1 published?

The published standard is dated September 2026 (V4.1.1, 2026-09).

Does WCAG 2.2 replace WCAG 2.1?

WCAG 2.2 is backwards compatible: a page that conforms to WCAG 2.2 also conforms to 2.1 and 2.0, with the one exception that criterion 4.1.1 Parsing has been removed.

Which WCAG 2.2 criteria can be tested automatically?

Of the six new A and AA criteria, only 2.5.8 Target Size (Minimum) is covered by a rule in axe-core. The other five need manual testing.

Do I need WCAG 2.2 level AAA?

No. EN 301 549 requires levels A and AA for web content. Level AAA criteria are listed in the standard for information only.

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