Does the EAA require WCAG 2.2? What EN 301 549 v4.1.1 changes

Short answer: not yet, and not by name. The European Accessibility Act (EAA) sets accessibility requirements. Standard EN 301 549 is the technical reference used to show that you meet them, and its web requirements are built on WCAG. The version in force today is EN 301 549 v3.2.1 (2021), which is based on WCAG 2.1 Level AA. A new version, v4.1.1, moves to WCAG 2.2 Level AA, but it does not become the reference until the European Commission cites it.

What has actually happened

• 2 September 2026: the Irish National Disability Authority reports the online publication of EN 301 549 V4.1.1, published by ETSI together with CEN and CENELEC. In its web content, non-web document and software clauses it references WCAG 2.2 Level AA instead of 2.1.
• Not binding yet. The same notice says publication is not the point at which v4.1.1 becomes legally binding. That happens once the Commission cites it, which the NDA currently expects on 16 December 2026. That is an expected date, not a confirmed one.
• Until then v3.2.1, based on WCAG 2.1, remains the reference. Once v4.1.1 is cited, conforming to it will give a presumption of conformity with the EAA.

What WCAG 2.2 adds at levels A and AA

WCAG 2.2 keeps every WCAG 2.1 requirement except one (4.1.1 Parsing, which is now obsolete) and adds six at level A or AA:

• 2.4.11 Focus Not Obscured (Minimum), AA: a focused element is not completely hidden, for example behind a sticky header or a cookie banner.
• 2.5.7 Dragging Movements, AA: anything done by dragging can also be done with a single pointer action.
• 2.5.8 Target Size (Minimum), AA: pointer targets are at least 24 by 24 CSS pixels, with exceptions.
• 3.2.6 Consistent Help, A: help options appear in the same place across pages.
• 3.3.7 Redundant Entry, A: people are not asked to enter the same information again in the same process.
• 3.3.8 Accessible Authentication (Minimum), AA: logging in does not depend on a cognitive test such as remembering or transcribing a password, and password managers and pasting must work.

The W3C designed WCAG 2.2 so that content conforming to 2.2 also conforms to 2.1. Working to 2.2 therefore does not put your 2.1 position at risk.

What to do now

1. Keep WCAG 2.1 AA as your baseline of record for contracts, reports and statements until the Commission cites v4.1.1.
2. Add the six new criteria to your checks now. They are small changes for most sites and they are what the next reference will ask for.
3. Do not promise "WCAG 2.2 compliance" or "EAA compliance" from a scan. Automated tools can test only part of these criteria (target size is the clearest automatable one). Focus visibility, dragging alternatives, consistent help and authentication need a person to check them.
4. Write the version into the paperwork. State which standard and version you tested against and on what date, so your documentation stays accurate when the reference changes.
5. Watch for the citation. When the Commission publishes it, update your contracts and templates. We will update this page too.

Next: read the EAA guide for agencies, use the WCAG checklist, or run a free automated check to see where a site stands. A scan is a starting point, not a verdict.