Real-time communication in EN 301 549 V4.1.1: what banks and contact centers need to know
Clause 6 of EN 301 549 V4.1.1 covers ICT supporting two-way real-time communication, not only voice calls. The standard significantly expanded real-time text (RTT, clause 6.2) requirements and added clause 6.7 on total conversation — simultaneous video, text and voice. For banks this means reviewing video calls with advisors, hotlines and in-app communication.
What changed in clause 6
In V3.2.1, clause 6 covered ICT with two-way voice communication. In V4.1.1 its title refers to two-way real-time communication. That is not just a rename: the foreword lists the rebuild of RTT requirements as one of the most important changes in the whole revision. More context: EN 301 549 V4.1.1 — what changed.
New elements of the clause are:
- operational scenarios 6.0.x that organize situations where requirements apply (including client side, system side, roaming, emergency connectivity),
- expanded clause 6.2 RTT, including responsiveness (6.2.4) and interoperability (6.2.10),
- new clause 6.7 total conversation.
RTT and total conversation in plain language
Real-time text (RTT) is text sent character by character as you type, not whole messages after pressing “send”. The other party sees what you write live, so the conversation runs at a pace close to speech. For Deaf, hard of hearing, and speech-impaired people this is the difference between a conversation and exchanging letters.
Total conversation is symmetric real-time transmission of video, text, and voice at the same time. It allows combining sign language with text or speech with text, depending on both parties’ needs.
Video call with an advisor
Standard requirements for video communication include among others a minimum frame rate: at least 20 frames per second. For someone communicating in sign language, image smoothness decides whether signs can be read at all.
Added to that are requirements on captions and controlling them in players (clause 7) and access to relay services (13.1.2), i.e. interpreter mediation in a call.
Which bank channels to review
Not every contact channel falls under clause 6 to the same extent. Definitions and preconditions of individual requirements decide applicability. In practice it is worth reviewing:
| Channel | What to focus on |
|---|---|
| Video call with advisor | Image quality and smoothness, ability to join an interpreter, real-time text alongside voice |
| Voice hotline | Text alternative, access via relay services, accessible tone menus |
| In-app calls | Clause 6 and 11 (software) requirements together, including user preferences |
| Chat with advisor | WCAG 2.2 requirements for the chat interface; scope of clause 6 to be verified |
Checklist for a bank
- Inventory all real-time contact channels: voice, video, text.
- For each, determine which clause 6 requirements apply and record the rationale.
- Check whether real-time text is available on voice calls.
- Verify video parameters and ability to enable a sign language interpreter (e.g. Polish Sign Language, PJM).
- Test the chat and video call interface with a screen reader and keyboard.
- Describe results in the service accessibility information required by the EAA (documents).
Book a consultation for your product team: we can identify which clause 6 requirements apply to your channels and plan testing as part of Accessibility PREMIUM. You can also contact us.
Frequently asked questions
Does chat on a bank website fall under clause 6?
That depends on whether it meets the definitions of real-time communication in the standard. The chat interface must always meet WCAG 2.2 as part of the website or app.
What is real-time text?
Text transmitted live, character by character, while typing.
Does the EAA cover banking services?
Yes, the European Accessibility Act covers consumer banking services.
Sources
- ETSI EN 301 549 V4.1.1 (2026-09)
- Deque: EN 301 549 V4.1.1 is final
- CAN/ASC EN 301 549:2024 (V3.2.1 requirements in HTML, for comparison)