EN 301 549 v4.1.1: v3.2.1 applies now, v4.1.1 and WCAG 2.2 come next

This page tracks one standard. For how it fits into EU law as a whole, see EU accessibility law for websites; for every jurisdiction we cover, see web accessibility laws worldwide.

What EN 301 549 is

EN 301 549 is the European standard for the accessibility of information and communication technology: websites, documents, software and other ICT products. For web content, its requirements follow the W3C's Web Content Accessibility Guidelines (WCAG), so in practice "meet EN 301 549" for a website mostly means "meet a specific version of WCAG at Level AA", plus a smaller set of requirements beyond WCAG.

EU law points to it in two places. Under the Web Accessibility Directive, which covers public sector sites, Commission Implementing Decision (EU) 2021/1339 cites EN 301 549 v3.2.1, and compliance with a cited harmonized standard "confers a presumption of conformity". Under the European Accessibility Act, the Commission's AccessibleEU center describes v3.2.1 as the current reference standard as well.

How EN 301 549 is organized

The standard is split into numbered clauses by type of technology. A website mostly falls under clause 9, but downloadable documents, apps, video players and support information each have their own clause. The titles below are from the v4.1.1 text published by ETSI.

Two examples of requirements that go beyond WCAG, both from v4.1.1:

• 9.7 User preferences for web pages: a web page must not block the browser's modes that present it according to the user's preference settings, or explicitly override user settings for documented platform accessibility features, unless that is essential to the page.
• 7.1.1 Subtitle playback: technology that displays video with synchronized audio must have a mode that displays the available subtitles.

Annex C of the standard sets out how to determine conformance with each requirement.

The two versions side by side

Sources: the ETSI publication of v4.1.1 and the European Commission's AccessibleEU announcement of September 7, 2026, which says "the current reference remains EN 301 549 v3.2.1 (2021), which is based on WCAG 2.1 Level AA."

What changed in v4.1.1

According to AccessibleEU, v4.1.1:

• Adopts WCAG 2.2 as the benchmark for websites, software and digital documents, adding the six new Level A and AA requirements from WCAG 2.2.
• Removes 4.1.1 Parsing, which the W3C has declared obsolete and removed from WCAG 2.2.
• Requires websites and documents to better respect users' accessibility preferences.
• Adds an annex linking its requirements directly to the European Accessibility Act. It is the first version developed specifically with the EAA in mind. Ireland's National Disability Authority adds that it also updates the mapping annex for the Web Accessibility Directive.
• Revises and extends the real-time text requirements in clause 6.2 to include total conversation, according to the list of significant changes in the standard itself. That list also confirms that clauses 9, 10 and 11 were updated to align with WCAG 2.2.

The six new Level A and AA criteria from WCAG 2.2 are:

WCAG 2.2 also adds three Level AAA criteria (2.4.12, 2.4.13 and 3.3.9), which sit outside the AA baseline. Our page on what is new in WCAG 2.2 explains each change with examples, and our list of all 86 WCAG 2.2 success criteria shows where they fit.

When v4.1.1 takes effect

A new version of a harmonized standard gives a presumption of conformity only once the European Commission cites it in the Official Journal of the European Union. The v4.1.1 text says the same: once cited under the EAA, meeting its relevant clauses confers a presumption of conformity "within the limits of the scope of the present document". Using the standard stays voluntary; it is one way to show you meet the law, not the only one. Until the citation happens, v3.2.1 is the reference, and AccessibleEU states that "there is no immediate legal requirement to comply with the new version."

Citation is expected in late 2026. The forecasts differ by several weeks: Ireland's National Disability Authority says it is "currently expected on 16 December 2026", and other published forecasts differ. Treat any specific date as a forecast until the citation appears in the Official Journal.

Where EN 301 549 applies

EU public sector, through the Web Accessibility Directive

Public sector websites and mobile apps covered by the Web Accessibility Directive are measured against v3.2.1 through the 2021 Implementing Decision. AccessibleEU says that once v4.1.1 is cited, meeting it will give a presumption of conformity with the directive.

Businesses under the European Accessibility Act

This point needs care. The 2021 citation of v3.2.1 was made for the Web Accessibility Directive. AccessibleEU describes v3.2.1 as the current reference for the EAA too, and says v4.1.1 "is not yet the legal reference standard for demonstrating compliance with the European Accessibility Act." Once v4.1.1 is cited, AccessibleEU says meeting it will give a presumption of conformity with both the EAA and the Web Accessibility Directive. In short: v3.2.1 is the working reference for EAA purposes today, and v4.1.1 is set to become the formal one. How a national authority treats a site in the meantime is a question for advice on your own facts.

Canada

Canada has adopted the standard as CAN/ASC-EN 301 549:2024. The federal Digital Technologies Phase 1 regulations apply clauses 4 to 7 and 9 to web pages, clauses 4 to 7 and 10 to digital documents, and clauses 4 to 7 and 11 to mobile apps, with requirements starting on December 5, 2027 and December 5, 2028. Our page on Canada accessibility law covers who is in scope.

What to do now

1. Build to WCAG 2.2 Level AA

   Each WCAG version keeps the earlier criteria, so meeting WCAG 2.2 AA also meets 2.1 AA. That covers v3.2.1 today and v4.1.1 once it is cited, with no rework. Our WCAG 2.2 checklist is the practical starting point, and which WCAG version you need sets out the version each law names.

2. Start with the six new criteria

   If you already build to WCAG 2.1 AA, the added work for 2.2 AA is the six new criteria above: typical problems are small tap targets, focus hidden under sticky headers, drag-only controls, and login steps that rely on memory.

3. Check what automation can and cannot see

   A free scan, the accessibility bookmarklet and the PDF checker find machine-detectable problems. Criteria that need judgment, such as whether alt text describes the image, need a person or a vision model; see our alt text checker, the deep audit and why rule scanners miss issues.

4. Say which version you test against

   An accessibility statement should name the standard and version. Our accessibility statement generator includes that field.