In September 2026 ETSI officially published EN 301 549 version 4.1.1, the latest European accessibility standard for ICT products and services. This version includes significant updates since EN 301 549 3.2.1 published in 2021.
EN 301 549 V4.1.1 is published as a harmonized European standard. However, citation of the standard in the Official Journal of the European Union (OJEU) is required for it to provide a formal presumption of conformity under EU legislation.
Key Highlights
For web, mobile application, document and software accessibility teams, the most visible change is moving from WCAG 2.1 to WCAG 2.2 under the Web, non-web document and non-web software requirements. For teams working on communication products and services need to understand and prepare for revised Real-Time Text requirements.
EN 301 549 V4.1.1 includes significant changes in these five areas:
- WCAG 2.2 success criteria being referenced in Clause 9, 10 and 11.
- Real-Time Text (RTT) requirements have been significantly revised in clause 6.2 and extended to include total conversation.
- Relationship between EN 301 549 requirements with the Web Accessibility Directive (Directive (EU) 2016/2102)) essential requirements on the accessibility of the websites and mobile applications of public sector bodies is documented in the new Annex ZA.
- Relationship between EN 301 549 requirements and the essential requirements of Directive (EU) 2019/882 on the accessibility requirements of products and services (The European Accessibility Act, EAA) is documented in Annex ZB
- EAA conformance evaluation of specific ICT products and services with the essential requirements of Directive (EU) 2019/882 on the accessibility requirements of products and services has been added in the new clause A.2.
WCAG 2.2 Alignment
6 New WCAG 2.2 Success Criteria:
EN 301 549 V4.1.1 references the new 6 success criteria introduced in WCAG 2.2 in clause 9, 10 and 11. The table below shows these requirements listed under each of these clauses.
| WCAG 2.2 Success Criteria | WCAG Conformance | Clause 9 Web | Clause 10 Non-web Documents | Clause 11 Non-web Software |
|---|---|---|---|---|
| 2.4.11 Focus not obscured (Minimum) | Level AA | 9.2.4.11 | 10.2.4.11 | 11.2.4.11 |
| 2.5.7 Dragging movements | Level AA | 9.2.5.7 | 10.2.5.7 | 11.2.5.7 |
| 2.5.8 Target size (Minimum) | Level AA | 9.2.5.8 | 10.2.5.8 | 11.2.5.8 |
| 3.2.6 Consistent help | Level A | 9.3.2.6 | 10.3.2.6 | 11.3.2.6 |
| 3.3.7 Redundant entry | Level A | 9.3.3.7 | 10.3.3.7 | 11.3.3.7 |
| 3.3.8 Accessible authentication (Minimum) | Level AA | 9.3.3.8 | 10.3.3.8 | 11.3.3.8 |
The following are important changes worth noting:
- Mobile web views: Web views embedded in mobile applications need to meet the requirements listed under clause 11 non-web software and don’t need to meet clause 9 Web requirements. Additionally, requirements of both clause 9 and clause 11 are not applicable together in any scenario. If at any point, there is an element of doubt then clause 11 non-web software requirements take precedence.
- User preferences: New sub-sections listing requirements related to User preferences have been included under 9.7 User preferences for web, 10.7 User preferences for non-web documents and 11.7 User preferences for non-web software respectively.
User’s preferences configured within browsers, software, document readers etc. should be respected and not overridden or blocked. Additionally, user’s preferences and documented platform accessibility features should be respected and should not be overridden or blocked unless it is essential for the information or functionality being provided.
Some platform accessibility features are also called out, such as colour filters, contrast, text size, pointer size, text cursor etc. that need to be respected and not blocked. - Parsing: WCAG success criteria 4.1.1 Parsing has been marked as “Void” in EN 301 549 V4.1.1 following its removal from WCAG 2.2.
Real-Time Text
In EN 301 549 V4.1.1 clause six includes significant changes, where Real-Time Text (RTT) requirements have been expanded to include support for total conversation, multiparty communication, stronger technical quality requirements as well as operational framework. Following are the key changes:
- Total conversation: Total Conversation requirements are included in clause 6.7 which means combine usage of voice, RTT and video support during a communication session.
- Interoperability: RTT interoperability requirements are included in 6.2.10. This will ensure that RTT can interoperate across different networks and different vendors as well as across communication clients and communication systems.
- Multiparty communication: RTT support has also been extended for multiparty communication.
- Technical requirements: Quality requirements related to RTT are included in:
- 6.2.4 RTT responsiveness
- 6.2.6 Processing rate of RTT
- 6.2.7 Character representation
- RTT input methods
- Operational framework: A detailed operational framework has been included in clause 6 that covers:
- 6.0.2 Communication client
- 6.0.3 Communication system
- 6.0.4 System connecting to another communication system
- 6.0.5 System with roaming visiting client
All in all, clause 6 has been revised significantly and expanded to support Real-Time Text communication.
Annex ZA - WAD
Annex ZA maps the requirements of EN 301 549 with the Web Accessibility Directive (WAD) that covers accessibility of public-sector websites and mobile applications. The Annex identifies EN 301 549 requirements applicable for public-sector websites, documents and mobile applications. It is an update to the WAD mapping provided in Annex A of EN 301 549 V3.2.1 with a revised structure in Annex ZA. The Annex primarily comprises of two tables:
Table ZA.1 –
- Covers requirements mapping for websites and documents.
- Refers primarily to the requirements outlined in clause 9 Web and 10 Non-web documents. It also refers to the relevant requirements of clause 5 Generic requirements, 6 ICT supporting real-time bidirectional communication, 7 ICT with video capabilities and 12 Information about product and services.
Table ZA.2 –
- Covers requirements mapping for mobile applications.
- Refers primarily to the requirements outlined in clause 11 non-web software. It also refers to the relevant requirements of clause 5 Generic requirements, 6 ICT supporting real-time bidirectional communication, 7 ICT with video capabilities and 12 Information about product and services.
Annex ZB - EAA
Annex ZB maps the requirements of EN 301 549 with the European Accessibility Act (EAA) requirements. This annex has been newly added in EN 301 549 to map the requirements with products and services covered under EAA. This annex comprises of 5 tables. Tables ZB.1 and ZB.2 are applicable to all products covered under the EAA.
| Annex ZB Table | EAA requirements covered |
|---|---|
| ZB.1 | Product information |
| ZB.2 | Product user interface and functionality |
| ZB.3 | Specific product categories |
| ZB.4 | All services |
| ZB.5 | Specific services |
EN 301 549 V4.1.1 also includes Annex ZC, which relates requirements from other EU directives to the clauses of EN 301 549.
Clause A.2 EAA Conformance Evaluation
A.2 is a new clause added in EN 301 549 V4.1.1. This clause provides a method to evaluate whether a specific ICT product or service meets the applicable EAA requirements.
The clause comprises of 5 tables that include EN 301 549 requirements applicable for the type of Information and Communication Technology (ICT) product or service being evaluated. So, if the ICT being evaluated for EAA conformance is a website or a web application then EN 301 549 requirements of clause 9 Web will be primarily applicable and those are listed in Table A.1.
| A.2 Tables | Type of ICT |
|---|---|
| A.1 | Web |
| A.2 | Non-web documents |
| A.3 | Non-web software |
| A.4 | Hardware |
| A.5 | All ICT |
What should organizations do now?
EN 301 549 V4.1.1 brings important changes across web, documents, software and communication technologies. Organizations should start reviewing the new requirements and understand what needs to change across their digital products and services.
It's time to start preparing for EN 301 549 V4.1.1 conformance!