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EN 301 549 V4.1.1: what's changing and when

Every clause page on this site is written against V3.2.1 - the edition currently cited in the EU Official Journal, and so the version with legal effect for EAA and Web Accessibility Directive presumption of conformity. But a newer edition, V4.1.1, has already been published by ETSI and is working its way toward taking over. This page covers what it changes and when it's expected to matter.

What's changing

V4.1.1's headline change is moving the web, non-web document and software clauses (9, 10 and 11) from WCAG 2.1 Level AA to WCAG 2.2 Level AA, adding six new success criteria that V3.2.1 doesn't require:

  • 2.4.11 Focus Not Obscured (AA) - a focused element can't be entirely hidden behind a sticky header, cookie banner or other overlay.
  • 2.5.7 Dragging Movements (AA) - any drag interaction needs a single-pointer alternative (e.g. tap-to-select instead of drag-to-reorder).
  • 2.5.8 Target Size (AA) - pointer targets need a minimum 24×24 CSS pixel hit area, with limited exceptions.
  • 3.2.6 Consistent Help (A) - help mechanisms (contact details, chat, FAQ links) must appear in the same relative order across pages.
  • 3.3.7 Redundant Entry (A) - information a user already entered in a process shouldn't have to be re-entered, unless it's essential.
  • 3.3.8 Accessible Authentication (AA) - cognitive function tests (e.g. puzzles, memorisation) used for login can't be the only authentication option, without an accessible alternative.

Beyond WCAG 2.2, V4.1.1 also substantially reworks Clause 6, widening it from "two-way voice communication" to real-time bidirectional communication more broadly - including expanded real-time text (RTT) requirements, interoperability between RTT implementations, and a "Total Conversation" model where voice, text and video can be used together in a single session. User-preference requirements are also reworked, and the standard's EAA and Web Accessibility Directive annexes have been updated to map against the revised clauses.

For clause-by-clause detail beyond this summary, see the standard itself - linked below - or the EN 301 549 overview for how V3.2.1's clause structure (which V4.1.1 keeps) fits together.

When it takes effect

V4.1.1 does not yet have legal effect, and there's no confirmed date for when it will. What's confirmed so far, from the published standard itself:

  • Published: 2 September 2026 (adopted by ETSI on 24 August 2026).
  • National standards bodies must publish V4.1.1 as an identical national standard, or endorse it, by 31 May 2027.
  • Conflicting national standards - including national editions of V3.2.1 - must be withdrawn by 31 May 2028. After that date, V4.1.1 is the only version in force nationally.

The step that actually matters for legal effect - citation of V4.1.1 in the EU Official Journal, which is what confers presumption of conformity under the EAA and Web Accessibility Directive - has no confirmed date. Some sources online cite specific dates (a recurring one is "October 2026"; some vendor write-ups have suggested other months) but none of these have a primary source behind them, and some appear to conflate the OJ citation with the unrelated national-standards deadlines above. Treat any specific date you see elsewhere as unconfirmed unless it links back to the Official Journal itself.

Until V4.1.1 is cited, V3.2.1 remains the version with current legal effect - see the timeline for the full chronology and sourcing on each date above.

Read the standard

Download EN 301 549 V4.1.1 (PDF, ETSI)

For the version currently in legal effect, see EN 301 549 V3.2.1 instead, or the EN 301 549 overview for a plain-language walkthrough of its clauses.