EN 301 549 v4.1.0 is in public enquiry, and it aligns with WCAG 2.2

EAA Comply · Published 27 July 2026 · 6 min read

EN 301 549 is the European standard that translates "accessible" from a legal aspiration into a testable list. If you are trying to comply with the European Accessibility Act, it is the document your auditor is working from, whether or not anyone has said so out loud.

A new draft version, v4.1.0, dated November 2025, is currently in ETSI's combined public enquiry and vote phase. It matters, it is not yet law, and the gap between those two statements is the whole point of this article.

What the draft changes

The headline change is alignment. In the draft, the requirements in clauses 9 (web), 10 (non-web documents) and 11 (software) have been updated to align with WCAG 2.2, and the standard normatively references the W3C's WCAG 2.2 recommendation as revised in December 2024.

This is also the first version written specifically against the EAA. The draft states its purpose as providing one voluntary means of conforming to the essential requirements of Directive (EU) 2019/882, under the European Commission's standardisation request C(2022) 6456 final (mandate M/587). Previous versions were built primarily around the public-sector Web Accessibility Directive.

What has not changed — and this is the part vendors gloss over

The version currently referenced in the Official Journal of the European Union is still v3.2.1. Until a new version is officially cited there, it does not carry the presumption of conformity. The European Commission states the position plainly: new versions of WCAG or of EN 301 549 do not automatically change member states' legal obligations.

Should you be building to WCAG 2.2 now?

Our view, and we will flag where it is a judgement call rather than a fact: yes, mostly, but for practical reasons rather than legal ones.

WCAG 2.2 is additive. It keeps everything in 2.1 and adds a small number of success criteria, most of which address problems that hurt real conversion on a real shop:

• Focus not obscured. A sticky header or a cookie banner covering the element the user has just tabbed to. Extremely common on e-commerce templates, and it makes keyboard checkout genuinely difficult.
• Target size. Minimum interactive target dimensions, which is a mobile-usability fix as much as an accessibility one.
• Dragging movements. Anything you can only do by dragging needs a non-dragging alternative. Relevant to sliders, image galleries and some configurators.
• Accessible authentication. No cognitive-function test — remembering, transcribing, solving a puzzle — without an alternative. This one has teeth for login and checkout flows.
• Consistent help and redundant entry. Do not make people re-enter information they have already given you in the same process.

Fixing these does not put you out of step with v3.2.1, because 2.2 does not remove anything 2.1 requires. It puts you ahead of where the standard is visibly heading, and the specific items involved are ones a customer would notice regardless of any legal obligation. That is why we test against WCAG 2.1 AA as the compliance baseline and flag WCAG 2.2 items separately in our reports, rather than blurring the two together.

And WCAG 3.0?

The W3C updated its WCAG 3.0 working draft on 3 March 2026. It remains a working draft. There is no published timeline to Recommendation status, and it has no compliance standing anywhere. WCAG 2.2 is still the current W3C Recommendation.

If a vendor is quoting WCAG 3.0 readiness at you as a reason to buy today, that is marketing. Nothing in the European legal framework references it, and nothing will for some time.

What to do with this

Treat v3.2.1 and WCAG 2.1 AA as the line you must be able to demonstrate you meet, because that is what the law currently points to. Treat the WCAG 2.2 additions as your next sprint, because they are cheap now, they are almost certainly where the standard lands, and several of them are fixing things that cost you completed purchases today.

Then write it down. An accessibility statement that names the standard and version you tested against, the date, the method, and the known remaining barriers is worth considerably more than one that claims perfection. Perfection claims are exactly what regulators have gone after: the FTC's $1 million order against accessiBe in 2025 turned on claiming a product could make any website WCAG-compliant when it could not.

• ETSI, Draft EN 301 549 V4.1.0 (2025-11), public enquiry and vote phase — etsi.org (PDF)
• European Commission, latest changes to the accessibility standard — digital-strategy.ec.europa.eu
• W3C WAI, WCAG 3.0 working draft update, 3 March 2026 — w3.org
• FTC, final order requiring accessiBe to pay $1 million, 22 April 2025 — ftc.gov