6 new WCAG 2.2 criteria in EN 301 549 and the end of criterion 4.1.1
EN 301 549 V4.1.1 adds six criteria from WCAG 2.2: 2.4.11, 2.5.7, 2.5.8, 3.2.6, 3.3.7 and 3.3.8. Each applies to three clauses at once: websites (9), documents (10) and software (11). Criterion 4.1.1 Parsing is marked as Void and is no longer evaluated.
Six criteria in one table
| WCAG 2.2 criterion | Level | Websites | Documents | Software |
|---|---|---|---|---|
| 2.4.11 Focus Not Obscured (Minimum) | AA | 9.2.4.11 | 10.2.4.11 | 11.2.4.11 |
| 2.5.7 Dragging Movements | AA | 9.2.5.7 | 10.2.5.7 | 11.2.5.7 |
| 2.5.8 Target Size (Minimum) | AA | 9.2.5.8 | 10.2.5.8 | 11.2.5.8 |
| 3.2.6 Consistent Help | A | 9.3.2.6 | 10.3.2.6 | 11.3.2.6 |
| 3.3.7 Redundant Entry | A | 9.3.3.7 | 10.3.3.7 | 11.3.3.7 |
| 3.3.8 Accessible Authentication (Minimum) | AA | 9.3.3.8 | 10.3.3.8 | 11.3.3.8 |
2.4.11 Focus not obscured: sticky headers and banners
When an element receives keyboard focus, it must not be fully hidden by content added by the page author. The most common culprits are sticky headers, footers with a chat button, and cookie banners. Someone navigating by keyboard moves on with Tab, and the focused element disappears under the header; they no longer know where they are.
How to test: tab through the entire page at different window widths and with the cookie banner open. The minimum version of the criterion requires the element to be at least partly visible.
2.5.7 Dragging movements: sliders, maps, boards
Any function operated by dragging must also be achievable with a single pointer action, without dragging (unless dragging is essential). This covers price sliders, reordering list items, panning a map, or task boards. Solutions include “up / down” buttons, fields to enter a value, or clicking the target point.
How to test: find every drag interaction and check whether the same effect can be achieved with one click or tap. Keyboard support alone is not enough: the criterion targets pointer users, e.g. mouse or touchscreen.
2.5.8 Target size: 24 by 24 pixels
A touch or click target must be at least 24 × 24 CSS pixels. A smaller target is allowed if there is enough free space around it: a 24 px diameter circle around it must not overlap other targets. Exceptions include links in text, elements whose appearance the author does not control (e.g. native browser controls), targets that have an equivalent larger counterpart, and cases where that size is essential.
How to test: measure header icons, close buttons, pagination, and footer links in browser developer tools. Some automated tools detect targets that are too small but do not always judge exceptions correctly.
3.2.6 Consistent help
If a help mechanism repeats across many pages of the site (contact details, contact form, chat, FAQ page), it must appear in the same order relative to other content. The criterion does not require adding help; it only requires that existing help does not “wander” on the page. This matters especially for people with cognitive disabilities.
3.3.7 Redundant entry
Information the user already provided in the same process must be auto-filled or available to select. A classic example is delivery address and billing address in a shop. Exceptions are when re-entry is essential (e.g. a memory game), required for security (e.g. password confirmation), or when earlier information is no longer valid.
3.3.8 Accessible authentication
Sign-in must not require a cognitive function test (remembering a password, transcribing a code, solving a puzzle) unless an alternative or assistance mechanism exists. In practice this means: allow pasting passwords and codes, do not block password managers, offer sign-in by link or passkey. The criterion allows object recognition and personal content tests (e.g. choosing your own photo).
How to test: go through sign-in, registration, password reset, and two-factor authentication. Check whether the password field allows paste, whether the password manager works, and whether CAPTCHA has an alternative.
4.1.1 Parsing: end of the criterion
In WCAG 2.2, criterion 4.1.1 was considered obsolete because modern browsers and assistive technologies cope with the syntax errors it addressed. V4.1.1 marks it as “Void”. In reports under the new version of the standard we no longer record a result for it. Problems that actually hinder users (e.g. duplicate IDs breaking field labels) are still caught by other criteria, e.g. 1.3.1 and 4.1.2.
What automation finds and what needs a tester
Automated tools help mainly with 2.5.8 (measuring targets) and partly with 2.4.11. Criteria 2.5.7, 3.2.6, 3.3.7, and 3.3.8 require a human to walk user paths: automation does not know which fields were already filled or whether sign-in relies on memory.
Want to check whether buttons on your site are the right size? Start with Accessibility CHECK. Sign-in, forms, and purchase flows are best examined in an expert Accessibility PRO test.
Frequently asked questions
What minimum button size does WCAG 2.2 require?
At AA level, at least 24 × 24 CSS pixels or adequate spacing from other targets.
Do we still need to test 4.1.1?
Not under WCAG 2.2 and EN 301 549 V4.1.1. Under V3.2.1, which remains the reference until the new version is cited, the criterion formally still applies.
Do the new criteria apply to PDF files?
Yes, through clause 10, taking into account WCAG2ICT guidance for documents.
Sources
- ETSI EN 301 549 V4.1.1 (2026-09)
- BarrierBreak: EN 301 549 V4.1.1
- To be added by editorial: W3C “What’s New in WCAG 2.2” and Understanding documents for each criterion