What changed on 2 September: EN 301 549 adopts WCAG 2.2

On 2 September 2026 a document appeared on the ETSI server that has since been written up as “WCAG 2.2 is out”. Two different things are being conflated, and it is worth separating them straight away: WCAG 2.2 came out in October 2023. What came out on 2 September is EN 301 549 V4.1.1, the European standard that adopts WCAG 2.2 and makes it the European technical bar for accessibility. The difference is not academic: it changes what you will one day have to demonstrate to a regulator, not what specialists already considered good practice.

Two documents, two dates

WCAG (Web Content Accessibility Guidelines) is a recommendation of the W3C. Version 2.2 reached W3C Recommendation status on 5 October 2023, and a revised Recommendation was published on 12 December 2024. No European or national obligation follows from that on its own, because the W3C is not a legislature.

EN 301 549 is a harmonised European standard issued by CEN, CENELEC and ETSI on a standardisation request from the European Commission. Version V4.1.1 carries 2026-09 in its header, gives 24 August 2026 as its date of adoption, and the file on the ETSI server is dated 2 September 2026. The previous version, v3.2.1, is from March 2021 and rests on WCAG 2.1. The link between the two is simple: the standard references WCAG and pulls its criteria into its own clauses.

What WCAG 2.2 adds over 2.1

Nine new success criteria. Six sit at level A or AA, the band actually required in Europe, and three at AAA, which no jurisdiction requires across the board:

One thing went the other way and disappeared: criterion 4.1.1 Parsing, on markup validity. The European standard says so in a note next to the corresponding requirement:

Earlier versions of the present document referenced the 4.1.1 Parsing success criterion from WCAG 2.0 and WCAG 2.1. In WCAG 2.2, this criterion has been removed, because the accessibility problems it was intended to prevent "either no longer exist or are addressed by other criteria".EN 301 549 V4.1.1, note to requirement 9.4.1.1

So duplicate id attributes and unclosed tags come off the report, at least as a 4.1.1 item. Every other criterion from 2.0 and 2.1 carries over unchanged, which makes WCAG 2.2 an addition, not a rewrite, and work done against 2.1 is not thrown away.

What is new in the European standard

The foreword of v4.1.1 lists five substantive changes against v3.2.1, and only one is about the web:

• The real-time text requirements in clause 6.2 were substantially revised and extended to cover total conversation.
• Clauses 9 (web), 10 (documents) and 11 (software) were aligned with WCAG 2.2. Per clause 9, conformance with WCAG 2.2 Level AA is equivalent to conforming with the corresponding clauses of the standard.
• A new Annex ZA maps the standard to Directive (EU) 2016/2102, the public sector web accessibility directive.
• A new Annex ZB maps the standard to Directive (EU) 2019/882, the European Accessibility Act. The previous version had nothing of the kind.
• A new clause A.2 provides five tables for evaluating a specific ICT product or service against the EAA.

Annex ZB is the biggest addition. The standard grew up serving the public sector and merely gestured at the EAA; now the EAA has its own mapping and evaluation tables. For an online shop it is the first document spelling out which parts apply to it.

Legally, nothing has changed yet

This is the step most write-ups skip. A harmonised standard does not take legal effect when it is published. It becomes something you can rely on when the European Commission cites it in the Official Journal. The standard says so about itself, in the future tense:

Once the present document is cited in the Official Journal of the European Union under that Directive, compliance with the normative clauses of the present document given in the tables in clause A.2 confers […] a presumption of conformity with the corresponding essential requirements of that Directive.EN 301 549 V4.1.1, foreword

Status as of 14 September 2026, checked against the European Commission's index of harmonised standards: under the public sector directive (2016/2102) the cited version is v3.2.1, harmonised on 18 August 2021, still the WCAG 2.1 one. Under the EAA (2019/882) the index carries no entry at all.

The second finding is worse than it looks and deserves to be said out loud: no standard confers a presumption of conformity with the EAA today, not the new one and not the old one. That is a negative finding, derived from what the Commission's list does not contain. Conforming to the standard therefore buys nobody legal certainty. It buys evidence, which is still worth having, but selling one as the other would be dishonest.

What has not changed is the obligation itself. EAA requirements have applied since 28 June 2025 through national transposition laws, they cover a closed list of products and services rather than “every website”, and some providers, micro-enterprises providing services in particular, are exempt. Whether your service is on that list is a question for a lawyer in your member state.

Three regimes, three versions of WCAG

If you sell on both sides of the Atlantic, notice that the version numbers do not line up. Merging them into one figure is how compliance programmes go wrong:

Do you need to do anything now?

Because of 2 September itself, no. No obligation was created and no clock started. What comes next is worth splitting into what is documented and what is expectation. Documented: the standard sets dates for national standards bodies: announcement by 30 November 2026, national adoption by 31 May 2027, withdrawal of conflicting national standards by 31 May 2028. There is also a precedent, in that v3.2.1 was published in March 2021 and cited on 18 August 2021, roughly five months later. Expectation, not fact: the usual course is that the Commission cites a revision within months, the reference bar moves to WCAG 2.2, and national rules and procurement documents follow. Whether and when that happens for v4.1.1 has not been announced, and the EAA starts from a different place, since not even the old version is cited there.

1. The obligation you already have is older than this standard. If your service falls within your national transposition, the requirements have applied since 28 June 2025. A new version changes that in neither direction.
2. Work against WCAG 2.2 cannot be wasted. The criteria from 2.0 and 2.1 are unchanged, so meeting 2.2 means meeting 2.1, whichever version the rules end up naming.
3. The new criteria land on things nobody was measuring. Sign-in flows (3.3.8), drag-only controls (2.5.7) and touch targets on mobile (2.5.8) are also where customers quietly give up, disability or not.

Where automation stops

One boundary to state plainly: automated testing finds part of the problems, not all of them. Whether alt text is meaningful, whether focus order makes sense, whether a task can really be completed from the keyboard: a machine does not judge any of that. No tool, ours included, can turn an automated scan into “your site conforms to WCAG” or “you comply with the EAA”. Torumata reports the share of automatically verifiable criteria with no error found, and says exactly that.

It earns its place by pulling the repeating faults out of a large site first, so the manual review starts from the remainder instead of from zero. Run a free audit.