EN 301 549 V4.1.1 and WCAG 2.2: what changes for websites
· 4 min read
EN 301 549 V4.1.1, published in September 2026, bases the web requirements of the European accessibility standard on WCAG 2.2 level AA instead of WCAG 2.1. For websites that means six additional success criteria at levels A and AA, and one criterion dropped. Until V4.1.1 is cited in the EU's Official Journal — expected in late 2026 — the harmonised version remains V3.2.1 (WCAG 2.1 AA).
Why EN 301 549 matters
The European Accessibility Act describes accessibility requirements in functional terms. To show that a website meets them, businesses rely on the harmonised standard EN 301 549: meeting a harmonised standard gives a presumption of conformity with the requirements it covers. Its chapter on web content simply incorporates WCAG success criteria. So when the standard moves from WCAG 2.1 to WCAG 2.2, the yardstick for EU websites moves too.
The timeline
| Step | Status |
|---|---|
| EN 301 549 V3.2.1 (WCAG 2.1 AA) | harmonised version cited in the Official Journal |
| EN 301 549 V4.1.1 (WCAG 2.2 AA) | published in September 2026 |
| Citation of V4.1.1 in the Official Journal | expected in late 2026 |
Until the citation, V3.2.1 is the reference for the presumption of conformity. After it, expect authorities, auditors and procurement to refer to V4.1.1. National transition arrangements may apply; check them for your country.
What is new: the six WCAG 2.2 criteria
WCAG 2.2 adds these criteria at levels A and AA:
2.4.11 Focus Not Obscured (Minimum) — AA
When an element receives keyboard focus, it must not be completely hidden by other content. On shops the usual suspects are sticky headers, cookie banners and chat bubbles that cover the focused link or button.
2.5.7 Dragging Movements — AA
Anything that needs dragging must also work with a single pointer action, such as a click or tap. Think of price range sliders, drag-to-reorder lists and swipe-only carousels. Add plus/minus buttons or input fields.
2.5.8 Target Size (Minimum) — AA
Clickable targets must be at least 24 × 24 CSS pixels, or have enough space around them, with exceptions such as links within a sentence. Typical shop issues: tiny quantity steppers, colour and size swatches, close icons and pagination dots.
3.2.6 Consistent Help — A
If you offer help — contact details, a chat, an FAQ link — it must appear in the same relative place on every page where it is offered.
3.3.7 Redundant Entry — A
Information the user already entered in the same process should be filled in automatically or be selectable. Classic example: "billing address same as shipping".
3.3.8 Accessible Authentication (Minimum) — AA
Logging in must not depend on a cognitive function test, such as remembering a password or solving a puzzle, unless an alternative or a mechanism to help is available. In practice: allow password managers and pasting, offer email or passkey login, and avoid puzzle CAPTCHAs without alternatives.
What was removed
4.1.1 Parsing is obsolete in WCAG 2.2 and removed. Modern browsers and assistive technology handle most markup errors themselves. Problems that still matter, such as duplicate IDs that break label associations, are covered by other criteria.
Does this change much for a typical shop?
If your site already meets WCAG 2.1 AA, the additional work is limited and fairly concrete: check focus against sticky elements, enlarge small targets, offer alternatives to dragging, keep help in a consistent place, avoid asking for data twice, and make login friendlier. Most of these are improvements your customers will notice anyway — larger targets and less retyping help everyone on a phone.
If your site has not been checked against WCAG 2.1 yet, start with the basics — labels, contrast, alt text, keyboard access — and include the 2.2 criteria in the same round. There is no reason to aim for the old version now.
What automation can and cannot check
Of the new criteria, target size can be partly checked automatically. Focus not obscured, dragging alternatives, consistent help, redundant entry and accessible authentication mostly need a person. That is one more reason why an automated scan is a starting point. Ours checks against WCAG 2.2 AA and maps each finding to both EN 301 549 V3.2.1 and V4.1.1 — and it remains an automated check, not a full audit, and not legal advice.
What this means for agencies
If you build or maintain sites for clients, update your definition of done: new templates should meet WCAG 2.2 AA from the start. Retrofitting target sizes and focus behaviour later costs more than designing them in. It is also a good moment to tell existing clients what changed — calmly, with a short list of concrete fixes rather than alarm.
What to do now
- Target WCAG 2.2 AA in new projects and redesigns.
- Add the six new criteria to your QA checklist — see our WCAG 2.2 checklist.
- Update your accessibility information when you change the standard you measure against. See the accessibility statement guide.
- Re-scan after the changes and keep monitoring.
For the legal context, read the EAA guide or the practical EAA guide for online shops. Run a free check to see where your site stands today.
Sources
- W3C, What's new in WCAG 2.2: https://www.w3.org/WAI/standards-guidelines/wcag/new-in-22/
- W3C, WCAG 2.2: https://www.w3.org/TR/WCAG22/
- National Disability Authority (Ireland), EN 301 549 published: https://nda.ie/news/en301549-published