Does EN 301 549 v4.1.1 apply now?

It is published, but it gives a presumption of conformity only once the EU cites it in the Official Journal. Until then the cited version is v3.2.1, which references WCAG 2.1 Level AA.

Which WCAG 2.2 criteria does v4.1.1 add?

The six Level A and AA criteria new in WCAG 2.2: 2.4.11 Focus Not Obscured (Minimum), 2.5.7 Dragging Movements, 2.5.8 Target Size (Minimum), 3.2.6 Consistent Help, 3.3.7 Redundant Entry and 3.3.8 Accessible Authentication (Minimum). It also removes 4.1.1 Parsing.

EN 301 549 v4.1.1: WCAG 2.2 becomes the EU benchmark, once it is cited

In September 2026 the European standards bodies ETSI, CEN and CENELEC published EN 301 549 v4.1.1, the harmonised standard behind the European Accessibility Act and the Web Accessibility Directive. If you sell digital products or services in the EU, this is the version your next audit will be measured against. Not quite yet, though, and that detail matters.

This post is a summary, not legal advice. The sources are linked at the end.

What changed

According to the European Commission's AccessibleEU Centre and the law firm Davis Wright Tremaine:

v4.1.1 adopts WCAG 2.2 as the accessibility benchmark for web content, replacing WCAG 2.1.
It adds six requirements from WCAG 2.2 and removes the obsolete 4.1.1 Parsing criterion.
It adds an annex that maps its requirements directly to the EAA, which makes it easier to show which clause answers which legal obligation.

What did not change yet

A harmonised standard only gives you a legal "presumption of conformity" once the EU cites it in the Official Journal. v4.1.1 has not been cited yet. Until it is, the cited version stays v3.2.1, which references WCAG 2.1 Level AA.

So, today:

An EU accessibility statement or VPAT that claims WCAG 2.1 AA against EN 301 549 v3.2.1 is still the formally correct baseline.
Work you do to meet WCAG 2.2 AA now is not wasted: WCAG 2.2 AA includes everything in 2.1 AA (except 4.1.1, which no longer applies), and it is where the standard is going.

We have seen a November 2026 citation date in blog posts, but we could not confirm it from an official source, so we would say "when it is cited" rather than give a date.

The six WCAG 2.2 criteria to check first

These are the Level A and AA criteria WCAG 2.2 added:

2.4.11 Focus Not Obscured (Minimum) (AA). A focused control must not be completely hidden, typically by a sticky header, cookie banner or chat widget.
2.5.7 Dragging Movements (AA). Anything you can do by dragging (sliders, reorderable lists, maps) also needs a way to do it with single clicks or taps.
2.5.8 Target Size (Minimum) (AA). Click and tap targets need to be at least 24 by 24 CSS pixels, or have enough space around them, with a few exceptions.
3.2.6 Consistent Help (A). If your pages offer help (a contact link, chat, an FAQ), it appears in the same relative place on each page.
3.3.7 Redundant Entry (A). Don't make people type the same information twice in one process, such as a shipping address at checkout.
3.3.8 Accessible Authentication (Minimum) (AA). Logging in must not depend on a memory or puzzle test unless there is an alternative; allowing password managers and paste usually covers it.

What to do now

Keep WCAG 2.1 AA as your reporting baseline for EU documents until v4.1.1 is cited, and say which version of EN 301 549 you report against.
Test the six criteria above now. Most are quick to check, and several (target size, focus hidden behind sticky bars) are common failures.
Check your login, checkout and help patterns, where three of the six live.

AccessiSight's EU editions report against EN 301 549 v3.2.1 today, and its WCAG 2.2 profile checks the new criteria where they can be tested automatically. See the EAA and EN 301 549 page for the current scope.

Sources: AccessibleEU Centre: the European accessibility standard EN 301 549 has been updated (7 Sep 2026) and Davis Wright Tremaine: European Accessibility Act ICT standards update (Sep 2026).