When does EN 301 549 V4.1.1 apply? Timeline and legal status
EN 301 549 V4.1.1 was adopted on 24 August 2026 and published on 2 September 2026. Presumption of conformity will only apply after citation in the Official Journal of the EU, expected around 30 November 2026. Until then, V3.2.1 remains the reference. National standards must adopt the new version by 31 May 2027 and withdraw conflicting standards by 31 May 2028.
Key dates
The standard itself gives dates that structure the transition period:
| Date | What happens |
|---|---|
| 24 August 2026 | Adoption of the standard by ETSI |
| 2 September 2026 | Publication of V4.1.1 |
| 30 November 2026 | Deadline for national standards bodies to announce the standard (doa); citation in the Official Journal of the EU is expected around this period |
| 31 May 2027 | Deadline for publication as a national standard or endorsement (dop/e) |
| 31 May 2028 | Deadline for withdrawal of conflicting national standards (dow) |
The date of citation in the Official Journal of the EU does not come from the standard; it depends on a decision by the European Commission. We give it based on industry sources and will update the article when citation appears.
Publication vs citation: what is the difference
Publication by ETSI means the standard exists and can be used. The legal effect in the EU comes only from publishing its number in the Official Journal of the EU as a harmonized standard. From that moment, a product or service conforming to the standard benefits from presumption of conformity with directive requirements.
Presumption of conformity in practice shifts the burden of proof. If you demonstrate conformity with the harmonized standard, the surveillance authority must show that you still do not meet directive requirements. Without a harmonized standard you must prove yourself that you meet every requirement.
Two directives, two annexes
V4.1.1 links to two directives through separate annexes:
- Directive 2016/2102 (WAD) on accessibility of public sector bodies’ websites and apps: Annex ZA describes the link.
- Directive 2019/882 (EAA) on accessibility requirements for products and services: Annex ZB describes the link, and clause A.2 allows assessing conformity of specific products and services.
For the public sector, the version currently cited is V3.2.1. For the EAA, V4.1.1 is the first prepared explicitly for that directive, in response to standardization request M 587.
What about Polish law?
In Poland, digital accessibility is regulated by two acts: the Act on digital accessibility of websites and mobile applications of public sector bodies (2019) and the Act of 26 April 2024 on ensuring that certain products and services meet accessibility requirements (implementing the EAA).
The key question is: do the laws point to a specific version of the standard, or to harmonized standards in general? If the reference is general, the new version may become the reference without amending the act, once it is cited in the Official Journal of the EU.
What to do until citation
The transition period is not a reason to wait. EAA obligations apply from 28 June 2025, and the content of V4.1.1 is already known. We suggest:
- Run audits against V3.2.1, but also test V4.1.1 requirements and describe them in a separate part of the report (methodology: Annex C).
- Plan new projects and major site changes for WCAG 2.2 and user preferences from the start.
- After citation, update conformance reports and documents published for customers (VPAT and statement).
Plan an audit that covers both versions of the standard: in Accessibility PRO we assess the current state under the applicable version and readiness for the new one.
Frequently asked questions
Does V4.1.1 already apply?
The standard is published and can be used, but it does not provide presumption of conformity until citation in the Official Journal of the EU.
What is presumption of conformity?
The principle that a product meeting a harmonized standard is deemed to meet directive requirements unless proven otherwise.
Is an audit under V3.2.1 still valid?
Yes, until the new version is cited that is the correct reference. It is still worth supplementing it with V4.1.1 requirements.
Sources
- ETSI EN 301 549 V4.1.1 (2026-09)
- Pivotal Accessibility: EN 301 549 V4.1.1 is published
- Deque: EN 301 549 V4.1.1 is final
- Act of 26 April 2024 (Journal of Laws 2024 item 731)