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EN 301 549 is being rewritten: what the WCAG 2.2 update means for your site

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EN 301 549 is being rewritten: what the WCAG 2.2 update means for your site

The European accessibility standard behind the EAA is moving from WCAG 2.1 to WCAG 2.2. What the six new requirements are — in shop-owner terms — and when they bite.

10 min read

Most businesses that dealt with the European Accessibility Act last year learned one equation: EAA compliance ≈ WCAG 2.1 AA. That equation is about to get a version bump.

The technical standard sitting between the law and WCAG — EN 301 549 — is being revised, and the new version swaps WCAG 2.1 for WCAG 2.2. If you've never heard of EN 301 549, we explain how the three layers fit together in WCAG vs EN 301 549 vs the EAA. The one-paragraph version:

EU Directive (EU) 2019/882 — European Accessibility ActThe law — defines who must comply and what happens if they don'tEnforceable since 28 June 2025 in all 27 EU member statesreferences for technical conformanceEN 301 549 v3.2.1 — European Harmonised Technical StandardThe technical specification — what accessible ICT must do▸ Chapter 9: Web content — adopts WCAG 2.1 Level AA in full▸ Chapter 10: Non-web documents — PDFs, e-books, Word files▸ Chapter 11: Software & mobile applications▸ Chapter 12: Support services & documentation(+ hardware, telephony, AV chapters for relevant products)Chapter 9 adopts WCAG 2.1 AA in fullWCAG 2.1 Level AA — W3C Web Content Accessibility Guidelines38 success criteria (Level A + AA) · Principles: Perceivable · Operable · Understandable · RobustPublished June 2018 · W3C/WAI · Not a law, but the technical baseline for web compliance

The EAA is the law. EN 301 549 is the harmonised European standard that gives you a presumption of conformity with that law. And WCAG is the web-content core embedded inside EN 301 549. Change the bottom layer, and every compliance checklist in Europe changes with it.

Where the revision actually stands

Precision matters here, because vendors are already selling "WCAG 2.2 is mandatory!" urgency. Here is the verifiable status:

MilestoneStatus
EN 301 549 v3.2.1 (embeds WCAG 2.1 AA)
In force
— the current harmonised version, cited in the Official Journal since 2021
WCAG 2.2 published by the W3C
Done
— October 2023
Draft EN 301 549 v4.1.0 (embeds WCAG 2.2 AA)
Published
— November 2025, by the joint ETSI/CEN/CENELEC body, for review
Final v4.1.1 adopted
Expected
— during 2026; also designed to support the EAA and update real-time-text requirements
Citation in the EU Official Journal (legal effect)
Expected
— industry sources point to late 2026; no official date confirmed. Only this step changes your legal presumption of conformity

Until that last row happens, WCAG 2.1 AA remains the legal reference point. But the content of the new version is already public — which means you can see next year's audit findings today.

The six new requirements, translated for a shop

WCAG 2.2 adds nine success criteria in total, but three are Level AAA (beyond what EN 301 549 requires of websites). The six that land at Level A/AA — the ones that will flow into EAA compliance — are below, each with the place it typically bites an online shop.

1. Target Size (Minimum) — 24×24 pixels to tap

Every interactive control needs to be at least 24×24 CSS pixels, or have enough spacing around it that the effective target is that size. Think of the and + quantity steppers in your cart, the tiny wishlist heart on product cards, star-rating widgets, or a row of footer social icons. If a user with tremor — or just a thumb on a phone — keeps hitting the wrong one, that's the failure this rule targets.

2. Focus Not Obscured (Minimum) — your sticky header can't hide the cursor

When someone tabs through your site with a keyboard, the element that has focus must remain at least partially visible. The classic offender: a sticky header or cookie banner that overlaps the focused link, so a keyboard user is typing into something they literally cannot see. If your shop uses a sticky announcement bar plus a sticky nav, this is worth testing this week.

3. Dragging Movements — sliders need a non-drag alternative

Anything operated by dragging — price-range sliders in filters, image-comparison widgets, sortable lists — needs a single-pointer alternative: type-in fields, plus/minus buttons, tap-to-set. Users with limited dexterity often can't perform a press-hold-move-release gesture at all.

4. Redundant Entry — stop asking twice

Information a customer already entered in a session must not be demanded again — auto-fill it or offer it for selection. The textbook e-commerce case: a checkout that asks for the shipping address, then presents an empty billing-address form with no "same as shipping" option. Annoying for everyone; a genuine barrier for users with memory or attention impairments.

5. Consistent Help — support lives in the same place on every page

If you offer a help mechanism — a contact link, phone number, chat widget, FAQ link — it must appear in the same relative place across pages. A chat bubble that's bottom-right on product pages but hidden in a hamburger menu during checkout fails. This is usually a template fix: one decision, applied everywhere.

6. Accessible Authentication (Minimum) — logins can't be memory tests

Signing in must not depend on a cognitive function test — memorising, transcribing, or puzzle-solving — unless there's an alternative. Distorted-text CAPTCHAs with no alternative, or "enter the 3rd, 5th and 7th character of your password" schemes, fail. Password-manager-friendly forms (allow paste!), magic links, passkeys, or email codes you can copy-paste all pass.

And one rule disappears

WCAG 2.2 removes 4.1.1 Parsing — the old requirement about valid, well-formed markup, made obsolete because modern browsers and assistive tech repair broken HTML themselves. If your last audit report listed parsing errors, those findings are already historical.

Notice what's not in the list of changes: everything else. All of WCAG 2.1's requirements carry over untouched. If you invested in alt text, contrast, keyboard navigation and form labels for the EAA deadline, none of that work is wasted — the new version is strictly additive (minus one rule).

Why act before the Official Journal citation

Three practical reasons, none of them fear-based:

  • The fixes are design-level and cheap when unhurried. Bumping tap-target sizes, adding a "same as shipping" checkbox, and unsticking a header from the focus path are small tickets. The same items done under a market-surveillance deadline — with legal review attached — cost multiples.
  • Regulators already scan against WCAG. As we found in our review of the EAA's first year, enforcement bodies select targets by automated scanning. When the reference standard bumps to 2.2, their tooling bumps with it — and your gap list grows overnight unless you closed it in advance.
  • The six additions are conversion fixes in disguise. Bigger tap targets, no repeated form entry, findable help, and paste-friendly logins reduce checkout friction for every customer. This is the rare compliance list you might have shipped anyway.

What to do this month

  1. Walk your checkout on a phone, thumb only. Every control you fumble is probably under 24×24px.
  2. Tab through your homepage and checkout with a keyboard. If the focused element vanishes behind a sticky bar, you've found a Focus Not Obscured failure.
  3. Audit your login. If a customer can't paste a password or has to solve a visual puzzle with no alternative, plan the alternative now.
  4. Check your filters and sliders for a type-in or button alternative to dragging.
  5. Scan for the WCAG 2.1 basics you may still be missing — the new criteria only matter once the current ones are handled.

Find your gap list before the standard changes

Webply scans your real pages against WCAG 2.1 AA today — including the keyboard and focus checks where most 2.2-era findings will cluster — and gives you a prioritised fix-list per page type. Free scan, no credit card, no overlay.

Related reading

Sources

This article is informational, not legal advice. Timeline entries marked "expected" reflect industry reporting as of 14 July 2026 and may shift; the legally binding standard remains EN 301 549 v3.2.1 until a successor is cited in the Official Journal of the EU.

EN 301 549
WCAG 2.2
Standards
EAA