EN 301 549 is the ICT accessibility standard that both the European Accessibility Act (EAA) and the European Union (EU) Web Accessibility Directive (WAD) point to, and it has been updated. The new version, published on September 2, 2026, brings the requirements for web content, mobile apps, documents, and software in line with WCAG 2.2 Level AA. The transition is underway, but it is not finished. Version 3.2.1, which incorporates WCAG 2.1 Level AA, is still the version cited in the Official Journal of the EU. That means it is still the version most EAA and WAD compliance programs are measured against.
So, what exactly does the standard say? What does the shift to WCAG 2.2 mean in practice? And how do you know which version to use today? We’ll answer these and more questions in this guide.
Key insights
What is EN 301 549?
EN 301 549 is the European standard that specifies accessibility requirements for ICT products and services. Three European standards bodies develop and publish it: the European Committee for Standardization (CEN), the European Committee for Electrotechnical Standardization (CENELEC), and the European Telecommunications Standards Institute (ETSI).
EN 301 549 is a standard rather than a law. It gives regulators, procurement teams, and testers a shared set of testable criteria that European accessibility legislation can point to.
The scope of EN 301 549 reaches well beyond websites. The standard sets requirements for hardware, non-web documents, non-web software, real-time communication, video, kiosks, and the information you publish about your products and services. Its clauses are self-scoping, which means each one opens with a condition. Where that condition is true for your product, the requirement applies to you.
The European Accessibility Act (EAA), Directive (EU) 2019/882, has applied to covered products and services since June 28, 2025. Conformance with the relevant requirements of EN 301 549 confers a presumption of conformity with the essential obligations of the directive. Version 4.1.1 was prepared under the Commission standardization request that supports the EAA, and it is the first version to directly map its clauses to the directive.
The Web Accessibility Directive (WAD), Directive (EU) 2016/2102, covers the websites and mobile apps of public-sector bodies. Public-sector organizations have been required to meet the standard for websites since September 23, 2020, and for mobile apps since June 23, 2021. Annex ZA of EN 301 549 has a dedicated mapping table that links the obligations in the standard directly to the WAD.
Which version of EN 301 549 applies to you right now?
Version 3.2.1, published in March 2021, remains the operative baseline for WAD and EAA compliance while the transition to the updated standard is underway. This version incorporates WCAG 2.1 Level AA for web content.
However, if you are scoping a conformance program this quarter, EN v4.1.1 is the requirement to prepare for. This new version is a final published standard rather than a draft, and the standard explicitly states that presumption of conformity follows once the document is cited in the Official Journal of the EU.
From publication to operational:
The EN 301 549 v4.1.1 timeline
The published standard carries fixed national incorporation dates. These are the dates national standards bodies work to, and they are stated in the front matter of the document.
| Milestone | Date | What it means |
|---|---|---|
| Adoption | CEN, CENELEC, and ETSI approved the final text. | |
| Publication | ETSI published v4.1.1. The text is stable and testable, but it is not yet the legal reference. | |
| Date of latest announcement (DOA) | National standards bodies announce the standard. Citation in the Official Journal is expected around this point. | |
| Date of publication or endorsement (DOP/E) | Deadline for national bodies to publish an identical national standard or endorse the EN. | |
| Date of withdrawal (DOW) | Deadline for withdrawing any conflicting national standard. |
Citation in the Official Journal is the milestone that matters for EAA and WAD compliance. Until that happens, treat v4.1.1 as an authoritative technical reference rather than the baseline for presumption of conformity.
What changed in EN 301 549 v4.1.1
Version 4.1.1 is a revision of v3.2.1, and the standard lists five significant changes since that release. Four of them may affect how you test.
The six new WCAG 2.2 Level A and AA criteria
Clauses 9, 10, and 11, covering web, non-web documents, and non-web software, now align with WCAG 2.2. For web content, WCAG 2.2 Level AA adds six success criteria at Level A and AA.
Clauses 9, 10, and 11, covering web, non-web documents, and non-web software, now align with WCAG 2.2. For web content, WCAG 2.2 Level AA adds six success criteria at Level A and AA:
The Real-Time Text (RTT) requirements in clause 6.2 have been substantially revised and extended to include total conversation, which is the simultaneous transfer of video, real-time text, and voice between participants in two or more locations. Clause 6 also adds operational scenarios for communication clients, communication systems, roaming users, and emergency communication. If your product includes voice or video calling, this is the most significant change in the release for your team.
The user preference requirements have been reorganized and clarified. Version 4.1.1 adds clause 9.7 for web pages and clause 10.7 for non-web documents, alongside the software requirement at clause 11.7. The practical effect is a clearer answer to a question that came up often under v3.2.1: how user preference requirements apply to content rendered in a browser.
Unlike earlier versions of EN 301 549, version 4.1.1 maps the standard to the requirements of the EAA and related regulations:
Annex ZB maps EN301 549 to the essential requirements of the EAA across five tables covering products, services, and specific services.
Clause A.2 supplies tables that let you evaluate a specific ICT product or service against the EAA.
Annex ZA is updated for the WAD.
Annex ZC relates requirements from other directives referenced by the EAA.
For compliance teams, the annexes are the practical payoff of this release. You can now trace an EAA obligation to the specific clauses that satisfy it, rather than building that mapping yourself.
Why WCAG 2.2 Level AA conformance is not EN 301 549 conformance
EN 301 549 incorporates WCAG, and WCAG 2.2 conformance is a large share of the work in meeting the new version of the European standard. However, conforming to WCAG alone doesn’t mean you’ve met every requirement.
WCAG sits inside three EN 301 549 v.1.1 clauses: 9 for web, 10 for non-web documents, and 11 for non-web software. The full European standard has 14 clauses. The requirements outside WCAG include:
How to test against EN 301 549, and what evidence to keep
Start by scoping. Because the clauses are self-scoping, your applicable requirement set depends on what your product actually does. Explore the clause list, record which conditions are true for you, and keep that record—it is the basis of every conformance claim you make later. Our EN 301 549 checklist gives you a starting structure.
Then test against the version that applies to you, and name that version in every artifact. Automated tooling covers a meaningful share of the clauses that incorporate WCAG. The remainder, including all of clauses 4 through 8 and 12 through 13, calls for manual evaluation with assistive technology. Annex C of the standard sets out sufficient means to determine conformance for each individual requirement, so an accessibility audit against EN 301 549 can point its procedures directly at the source.
Conformance documentation written against v3.2.1 will need re-evaluating against v4.1.1. That includes Voluntary Product Accessibility Template (VPAT®) reports, also called accessibility conformance reports (ACRs), and the accessibility statements you publish under the EAA or WAD. Plan for a re-issue rather than a footnote.
This documentation is vital, because compliance and business risk doesn’t just hinge on whether you meet the new criteria. It depends on whether you can produce current evidence of where you stand, on the day a regulator or a customer asks. Evidence that is a year old and pinned to a superseded version answers a different question than the one you were asked.
Adopt these four habits to make that evidence hold up:
Know where you stand
against EN 301 549
Staggered national timelines for when the new version goes into effect and a standard that reaches well past the web make EN 301 549 conformance a planning challenge as much as a testing challenge. The organizations that handle the v4.1.1 transition well will be the ones that already know which clauses apply to them and can show current results against each one.
Level Access has supported organizations through European accessibility requirements for more than two decades, combining automated testing, manual evaluation by experts and people with disabilities, training, and legal expertise. Our team tests against EN 301 549 in full, including the non-web clauses that WCAG does not reach, and produces the documentation your customers and regulators ask for.
To find out how your digital experiences measure up against the version of the standard that applies to you, request a free risk assessment.
Frequently asked questions
What is the current version of EN 301 549?
Version 3.2.1 is the version cited in the Official Journal of the European Union today, and it remains the operative baseline. The updated EN 301549 v 4.1.1 published on September 2, 2026, and citation is expected around late 2026. Until it happens, conformance claims should name v3.2.1 as the version tested.
What changed in EN 301 549 v4.1.1?
Four changes matter most. Clauses 9, 10, and 11 now align with WCAG 2.2, which adds six Level A and AA success criteria for web content. Clause 6 has been substantially revised to cover real-time text and total conversation. User preference requirements were reworked, and new annexes map the standard to the EAA for the first time.
When do I have to comply with EN 301 549 v4.1.1?
It depends on the Member State(s) where you have consumers. Once v4.1.1 is cited in the Official Journal, conformance with it confers a presumption of conformity under the EAA.
Is EN 301 549 the same as WCAG?
No. EN 301 549 incorporates WCAG as its baseline for web content, non-web documents, and non-web software, then adds requirements for hardware, real-time communication, video, product information, and relay services. WCAG conformance is necessary for EN 301 549 conformance; however, depending on your product, it might not be sufficient on its own.
Does EN 301 549 apply to non-EU companies?
Yes, if you place covered products or services on the EU market or offer them to consumers in the EU. The EAA applies based on where a product or service is offered, not on where your organization is headquartered, and conforming with EN 301 549 is the best way to demonstrate EAA compliance.
My product is already ADA compliant. What is the gap?
If you comply with the ADA, your digital experiences most likely conform to WCAG 2.1 or 2.2 Level AA, which covers the web clauses of the standard. The gap is the non-web ICT requirements: hardware, non-web documents, non-web software, product information, and clause 6 if your product includes communication features. It could also include user preferences, video player requirements, and—if your product is an authoring tool—a set of tool-specific requirements.
Do I need to re-issue my VPAT?
Conformance documentation written against v3.2.1 will need re-evaluating against v4.1.1, including completed VPATs (accessibility conformance reports). Re-testing against the revised clauses is the only way to make an accurate claim about the newer version.