WCAG 2.2 in the new EN 301 549: what changed and what to do on your site
ETSI has published EN 301 549 V4.1.1, moving the European accessibility standard to WCAG 2.2. What changes for shops under the EAA, six new criteria and a checklist for now.
On 2 September 2026 ETSI published EN 301 549 V4.1.1, and the European accessibility standard now builds its web requirements on WCAG 2.2 instead of WCAG 2.1.
What changed in the standard
EN 301 549 is the technical standard behind the European Accessibility Act, Directive (EU) 2019/882 (EUR-Lex), which has applied since 28 June 2025 and covers, among other things, e-commerce services for consumers. Microenterprises providing services are exempt. In ETSI, version V4.1.1 moves the web requirements from WCAG 2.1 (the basis of V3.2.1) to WCAG 2.2 levels A and AA and includes an explicit mapping to the EAA requirements in Annex ZB. WCAG 2.2 also removes criterion 4.1.1 Parsing as obsolete, so one old check disappears.
Six new criteria and what they mean in a shop
Compared with 2.1, WCAG 2.2 adds six success criteria at levels A and AA:
| Criterion | Level | What to check |
|---|---|---|
| 2.4.11 Focus Not Obscured (Minimum) | AA | A sticky header or banner must not cover the field that has keyboard focus. |
| 2.5.7 Dragging Movements | AA | Sliders and drag-only controls, such as a price filter, need a click or tap alternative. |
| 2.5.8 Target Size (Minimum) | AA | Small icon buttons in the cart are at least 24 by 24 CSS pixels, with exceptions. |
| 3.2.6 Consistent Help | A | The help or contact link sits in the same place on every page. |
| 3.3.7 Redundant Entry | A | Do not ask the customer to retype data already given, for example the shipping address at checkout. |
| 3.3.8 Accessible Authentication (Minimum) | AA | Login without cognitive tests, or with an alternative (paste from clipboard, password manager). |
What applies today
For the EAA, no harmonised standard reference has been published in the Official Journal of the EU yet. In practice businesses use EN 301 549 V3.2.1 (WCAG 2.1), which is cited for public-sector websites under Directive 2016/2102. According to specialists (Deque), citation of V4.1.1 is expected around the end of November 2026, with no official notice yet. Building to 2.2 now avoids rework.
What to do now
- Check the cart, checkout and login against the six new criteria first: that is where shoppers drop off and where most of them apply.
- Once V4.1.1 is cited, update your accessibility statement to reference WCAG 2.2 and EN 301 549 V4.1.1.
- Add meaningful alt text to product images.
- Test keyboard navigation: every control reachable, and the focus always visible.
- Test the shop on a phone, including tap target sizes.
- Keep a record of what you found and fixed, with dates.
Free PromoPilot tools can help with parts of this, for example the alt text generator for product images and the mobile-friendly test. They do not replace a WCAG audit. This is general information, not legal advice.
Sources: ETSI, EN 301 549 V4.1.1, 2 September 2026; EUR-Lex, Directive (EU) 2019/882; W3C, WCAG 2.2. Retold by the PromoPilot team.
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