EN 301 549 V4.1.1: what changed compared to V3.2.1
EN 301 549 V4.1.1 was published on 2 September 2026. It is the first major revision of the European ICT accessibility standard since March 2021. The standard now references WCAG 2.2, adds user preference requirements (9.7, 10.7, 11.7), rebuilds real-time text requirements, and adds annexes linking it to the European Accessibility Act. Presumption of conformity will only apply after citation in the Official Journal of the EU.
Why a new version?
EN 301 549 is the standard used in the European Union to assess the accessibility of websites, applications, documents, software, and hardware. The previous version, V3.2.1, was created mainly for public procurement and the Web Accessibility Directive (WAD). It was based on WCAG 2.1.
Since then, two things have changed. W3C published WCAG 2.2, and on 28 June 2025 the European Accessibility Act (EAA) began to apply, covering private companies too: banks, online shops, carriers, and communication service providers. Version V4.1.1 is the response to both processes.
What the standard itself says
In the foreword to V4.1.1, ETSI lists the main changes compared with V3.2.1. In our own words, they are:
- Significantly rebuilt and expanded requirements for real-time text (RTT) in clause 6.2, together with new requirements for so-called total conversation.
- Updated requirements in clauses 9 (websites), 10 (documents), and 11 (software) to WCAG 2.2.
- A new Annex ZA showing how the standard relates to the requirements of Directive 2016/2102 (WAD).
- A new Annex ZB linking the standard to the requirements of Directive 2019/882 (EAA).
- A new clause A.2 that allows assessing conformity of specific products and services with the EAA.
Changes visible in the text itself
Comparing the first pages of both versions shows how much the centre of gravity of the standard has shifted.
| Element | V3.2.1 (2021) | V4.1.1 (2026) |
|---|---|---|
| Basis | Phase 2 of Mandate M 376 | Standardization request M 587 |
| Keywords | accessibility, HF, ICT, procurement | accessibility, HF, ICT, product, service |
| Scope | “Functional” accessibility requirements | Accessibility requirements, listing audiences including market surveillance authorities |
| Addressees | Buyers, developers, and producers of ICT | Also sellers, importers, and distributors |
| Annexes | 6 | 8 (including new ZB and ZC) |
| WCAG | 2.1 | 2.2 (ISO/IEC 40500:2025) |
The disappearance of the word “procurement” and the appearance of importers and distributors is not cosmetic. These are exactly the entities the EAA places obligations on. The new Annex ZC shows how requirements from other directives map to clauses of the standard.
It is also worth noting that only the word “functional” dropped out of the scope. Test procedures remain: the standard still describes how to check each requirement (we cover this in the article on Annex C).
New references: WCAG 2.2, WCAG2ICT, and PDF/UA
The normative reference is WCAG 2.2, the W3C recommendation of 12 December 2024, also adopted as ISO/IEC 40500:2025. WCAG 2.0 and 2.1 moved to informative references.
Informative references also gained the new WCAG2ICT version from December 2025, which explains applying WCAG to documents and software, and the PDF/UA-1 and PDF/UA-2 standards. For PDF document auditors this is an important signal: the standard explicitly points to where to find technical requirements for accessible PDF files.
New WCAG 2.2 criteria and removed 4.1.1
Clauses 9, 10, and 11 gain six criteria: 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, and 3.3.8 Accessible Authentication (Minimum). Criterion 4.1.1 Parsing is marked as “Void”, as in WCAG 2.2. We describe the details in a separate article on new WCAG 2.2 criteria.
A requirement outside WCAG: user preferences
New sub-clauses 9.7, 10.7, and 11.7 require websites, documents, and software not to override or block user accessibility settings such as colour filters, contrast, text size, pointer size, or text cursor. The exception is when overriding is essential for content or function.
This requirement does not come from WCAG 2.2, so a “pure WCAG” audit will not cover it. Previously a similar clause existed only for software (11.7). More in the article on user preferences.
The standard also clarifies the status of web views embedded in mobile apps: they are assessed under clause 11 (software), not 9.
New and relocated clauses
| Clause | What changed |
|---|---|
| 5.1.8 | New: identification of field purpose in closed functionality |
| 5.10 | Authoring tools in the general part (in V3.2.1 they were in 11.8) |
| 6 | New title: ICT supporting two-way real-time communication; 6.0.x scenarios; expanded 6.2 RTT; new 6.7 total conversation |
| 9.7, 10.7 | New: user preferences for websites and documents |
| 12.4–12.5 | New: electronic programme guides (EPG) |
| 13.2 | Marked as “Void”; relay service access in 13.1.2 |
| 14.2 | New: special states |
| Annex E | New guide to the standard |
What to do now
Until V4.1.1 is cited in the Official Journal of the EU, V3.2.1 remains the reference point (we describe the timeline in a separate article). This is a good moment for three steps:
- Review your latest audit and check whether it covered WCAG 2.2 criteria.
- If you have a mobile app, plan user preference tests on real devices.
- Update documents: conformance report, accessibility statement, or service accessibility information (see report, VPAT, and statement).
Want to see how your site measures up against WCAG 2.2? Start with Accessibility CHECK or talk to us about what the new standard means for your organization.
Frequently asked questions
How does V4.1.1 differ from V3.2.1?
It references WCAG 2.2 instead of 2.1, adds user preference requirements, rebuilds clause 6 on real-time communication, and includes annexes for the EAA.
Does V3.2.1 still apply?
Yes. Until the new version is cited in the Official Journal of the EU, V3.2.1 provides presumption of conformity.
Do I need to repeat the audit?
Not immediately. It is still worth checking whether your last audit covered WCAG 2.2 and planning to add the new requirements.
Sources
- ETSI EN 301 549 V4.1.1 (2026-09)
- ETSI EN 301 549 V3.2.1 (2021-03)
- Deque: EN 301 549 V4.1.1 is final
- BarrierBreak: EN 301 549 V4.1.1