EN 301 549 Version 4.1.1: What Changes, and When It Applies to You

The Version You Must Comply With Today

The current legally recognised EN 301 549 version is V3.2.1, published in March 2021, built on the Web Content Accessibility Guidelines (WCAG) 2.1 AA.

WCAG 2.2 has been out since October 2023 – a real gap already exists. Closing it is underway: V4.1.1, the next EN 301 549 edition (currently in draft as V4.1.0), is expected around November 2026 and will adopt WCAG 2.2 AA.

Your obligations stay anchored to what's currently cited, though. The European Commission has been explicit: legal obligations shift only when a standard is formally cited in the Official Journal of the European Union (OJEU) – publishing a new version, or a new WCAG, isn't enough on its own. V3.2.1 is currently that cited version.

What's Coming: V4.1.0 and V4.1.1

A new edition has moved through the standardisation process:

• November 2025 – draft V4.1.0 released for public review
• June 2026 – V4.1.0 reached final draft status
• August 2026 (scheduled, per ETSI's own Work Programme) – final version V4.1.1 publication
• 30 November 2026 (scheduled, per ETSI's own Work Programme) – V4.1.1 citation in the Official Journal, replacing V3.2.1 as the legally recognised standard.

That November date is a scheduled milestone, not a guarantee. Standardisation timelines routinely shift at this stage – citation depends on a final vote, European Commission review, and formal OJ publication, each of which can move the date by weeks or months. Until citation happens, V4.1.0 is a draft under review – worth preparing for, not something to certify against today.

What Actually Changes

As already mensioned, web content moves from WCAG 2.1 to WCAG 2.2. Clauses 9, 10, and 11 – covering web, non-web documents, and software – adopt WCAG 2.2 AA as the baseline. That adds new success criteria not present in the current standard, covering areas like target size and accessible authentication.

This doesn't make EN 301 549 equivalent to WCAG, though. Even with WCAG 2.2 folded in, the standard still carries dozens of EN-specific requirements WCAG doesn't cover at all – see our breakdown of what EN 301 549 requires beyond WCAG.

Clause 6 is substantially rewritten. It broadens from "two-way voice communication" to "real-time bidirectional communication," and now formally includes Total Conversation – the integration of voice, real-time text (RTT), and video. RTT requirements themselves are significantly revised and extended.

Two new annexes map the standard directly to the EAA. Annex ZA and Annex ZB explicitly connect EN 301 549's technical clauses to the legal articles of the EAA. Annex ZA also updates the previous Annex A, covering the WAD. A new clause A.2 is added specifically to let EAA-scoped products and services be evaluated for conformance – closing a structural gap the current V3.2.1 doesn't fully address for the EAA.

Structural clean-up. Hardware, documentation, and support-service clauses are reorganised for clarity, without changing their substance.

Why the EAA Mapping Matters

This is the most consequential change for many organisations. Right now, EN 301 549 V3.2.1 predates the EAA and isn't formally mapped to it – it's still a strong technical resource for meeting EAA requirements, but it doesn't yet carry a formal presumption of conformity under that directive.

V4.1.1's new annexes are built specifically to close that gap. Once cited in the Official Journal, conforming to EN 301 549 will map directly onto EAA obligations – not just WAD ones.

What to Do Now

• Haven't evaluated against EN 301 549 yet? Evaluate against V3.2.1 – it's the version currently cited in the Official Journal and the one that actually carries legal weight. Don't wait for V4.1.1.‍
• Already evaluated against V3.2.1? Start scoping a gap assessment for the V4.1.0 delta – the added WCAG 2.2 AA success criteria and the expanded clause 6 real-time text and Total Conversation requirements – so you're ready to close the gap quickly once V4.1.1 is cited, instead of starting cold.‍
• Don't treat V4.1.0 as binding today. It isn't, yet – and won't be until V4.1.1 is cited in the Official Journal.‍
• Track the citation date, but don't lock to it. ETSI's own schedule currently targets 30 November 2026 – treat that as the current milestone, not a fixed deadline, and confirm before assuming it has taken legal effect.

For binding legal requirements, always check the current text of the WAD, the EAA, and the version of EN 301 549 currently cited in the Official Journal of the EU.