Adam Fenwick

EN 301 549 V4.1.1 Explained: WCAG 2.2 & Compliance

A new version of EN 301 549 has been published, introducing WCAG 2.2 criteria and stricter accessibility guidance for digital documents.

ETSI has published a new version of the European accessibility standard, EN 301 549 V4.1.1. This brings requirements up to date with WCAG 2.2 across websites, software, and digital documents. The European Commission currently still references V3.2.1 (meaning V4.1.1 is not the new legal reference yet), here is what has changed..

Why care about V4.1.1 now?

V4.1.1 is the first version of the standard built specifically to support the European Accessibility Act (EAA).

When V4.1.1 becomes official, conforming to EN 301 549 gives organisations a presumption of conformity with both the EAA and the Web Accessibility Directive.

Key changes in EN 301 549 V4.1.1

The core update swaps the WCAG baseline referenced from WCAG 2.1 to WCAG 2.2. This isn't just a website change, it includes documents (PDFs, Office files) and native software too.

Six new WCAG 2.2 success criteria:

  • 2.4.11 Focus Not Obscured (Minimum) - AA
  • 2.5.7 Dragging Movements - AA
  • 2.5.8 Target Size (Minimum) - AA
  • 3.2.6 Consistent Help - A
  • 3.3.7 Redundant Entry - A
  • 3.3.8 Accessible Authentication (Minimum) - AA

More about what’s new in WCAG 2.2

Respecting users preferences

Digital products must not block or override user-selected operating system or browser settings.

  • Font Size & Text Scaling: Products must not block or override a user's platform-level text-size preference. For example, fixed font sizes that ignore browser zoom, or viewport settings that disable pinch-to-zoom.
  • Dark Mode & Contrast Themes: Products can no longer override the dark mode, inverted colours, or high-contrast preferences exposed by the user's browser or platform. Custom styles must respect these settings rather than forcing a fixed theme.

More Real-Time Text requirements

V4.1.1 expands the real-time communication rules. Real-Time Text (typed text sent live, as an alternative to speaking) must now work across different providers’ systems and support group calls. In a video call, 'Total Conversation' must be supported to ensure users can talk, see video, and type all at the same time, rather than switching between them.

What should you do now?

Because V3.2.1 remains the legally cited standard, there's no compliance deadline yet. You should probably get ahead of it though, here are few way how:

  • Audit against the six new WCAG 2.2 success criteria
  • Check where you're overriding platform preferences
  • Factor V4.1.1 into procurement and roadmap planning now

There's no confirmed date yet for when V4.1.1 will be made official, so V3.2.1 and WCAG 2.1 remain the legal standard for now. But WCAG 2.2 has been stable since 2023. Working toward it today is really just early compliance with what's coming, rather than waiting until it is here.

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