Has EN 301 549 been cited for the European Accessibility Act?
Adopted is not published. Published is not cited. Only the last one creates a presumption of conformity, and it has not happened yet. This page tracks where the standard actually is, and shows how we check.
The answer
Status as of 17 October 2026: no.
No harmonised standard has been cited in the Official Journal under Directive (EU) 2019/882, the European Accessibility Act. There is no presumption of conformity available under Article 15 of that Directive.
EN 301 549 is cited in the Official Journal — under the Web Accessibility Directive (EU) 2016/2102, which covers public sector bodies. Different Directive, different scope, different legal effect.
We check this weekly and date every change.
Where the standard has actually got to
- Final draft issued. Done, June 2026.Legal effect: none.
- Adopted by the national standardisation bodies. Done, 24 August 2026. This is the step being reported as the standard being ready.Legal effect: none.
- Published by ETSI. Done, 2 September 2026, as V4.1.1, a day earlier than the work programme scheduled. The document is now a published European standard rather than a draft.Legal effect: none.
- Delivered to the European Commission. Done, 23 September 2026. ETSI’s schedule records delivery to the Commission, the step before any citation.Legal effect: none.
- Cited in the Official Journal under Directive (EU) 2019/882. Not reached. ETSI’s project schedule targets 16 December 2026; the Commission has published no date.The only step that creates a presumption of conformity.
Three dates in the published standard are not Official Journal citation. V4.1.1 lists 30 November 2026 as its date of announcement, with 31 May 2027 for national publication and 31 May 2028 for withdrawal of conflicting national standards. These are national standardisation body dates. None of them is citation under Directive (EU) 2019/882, and none of them creates a presumption of conformity. Expect 30 November 2026 to be reported as the date the standard becomes binding under the Accessibility Act. It is the standard’s own date of announcement, and in early September it was also the date ETSI’s project schedule targeted for citation in the Official Journal. Pivotal Accessibility quoted 30 November from that schedule on 3 September; it now reads 16 December 2026. If citation happens, presumption of conformity under the Act begins then. A target is not a decision, and this one has already moved once.
How we checked
| Source | What we asked | What came back |
|---|---|---|
| Commission harmonised standards index | Which legislation has harmonised standards published in the Official Journal | One entry under Accessibility, for Directive (EU) 2016/2102. None for 2019/882 |
| EUR-Lex, legal acts | Exact phrase “in support of Directive (EU) 2019/882” | No results. Standardisation request M/587 (C(2022) 6456 final, 14 September 2022) does carry that phrase in its title, but it is not in the EUR-Lex full-text index and it is a request to draft standards, not a citation. If this query ever returns a hit, read which document it is before concluding anything |
| EUR-Lex, same query shape, control | Exact phrase “in support of Directive (EU) 2016/2102” | 12 results, including Implementing Decisions (EU) 2018/2048 and (EU) 2021/1339 |
| EUR-Lex, full text | “EN 301 549”, all collections, newest first | Nothing in 2024 to 2026 citing it under the Accessibility Act |
| EUR-Lex, freshness control | Exact phrase “EN 18286”, newest first | Commission Implementing Decision (EU) 2026/2274, found within three days of its publication on 14 October 2026. The index is current enough to show a recent citation. |
| The standard’s own front matter | Does it claim citation | No. It reads “Once the present document is cited in the Official Journal”, which is conditional |
| ETSI project schedule, work item 64282 | Target date for citation in the Official Journal | “Citation in the OJ” targeted 16 December 2026, not yet achieved. Pivotal Accessibility quoted 30 November from the same schedule on 3 September. The schedule is a JavaScript application and returns an empty page to an ordinary fetch, so it was read in a rendering browser |
A search returning nothing proves nothing on its own, because an empty result is equally consistent with a broken query. Running the same query shape against the Web Accessibility Directive returns twelve results. That is what makes the empty result a real absence rather than a failed search.
What changes on the day it is cited
Conforming to the cited version will confer a presumption of conformity with the Act’s requirements, within the scope of the standard. That will be the first time such a presumption is available under this Directive.
Two things will not change, and both are quotable from the Commission’s own page.
Harmonised standards remain voluntary. The Commission states that “the use of these standards remains voluntary”, and that an operator is free to choose another technical solution.
The obligation does not move. The EAA has applied since 28 June 2025. Citation creates a route to demonstrating conformity. It does not create a deadline, and anything describing it as a new deadline is wrong.
Which six criteria
WCAG 2.2 adds nine criteria in total. Three are Level AAA and sit outside the conformance requirement, so six is the number that affects you. The standard settles this itself: conformance with WCAG 2.1 Level AA equals all of clauses 9.1 to 9.4 except 9.2.4.11, 9.2.5.7, 9.2.5.8, 9.3.2.6, 9.3.3.7 and 9.3.3.8. That exception list is the delta.
- Focus Not Obscured, Minimum (2.4.11, AA). When a keyboard user tabs to a control, it must not be entirely hidden behind a sticky header, a cookie banner or a chat widget.
- Dragging Movements (2.5.7, AA). Anything you can do by dragging must also be possible without dragging. Sliders and reorderable lists are the common cases.
- Target Size Minimum (2.5.8, AA). Tap targets must be at least 24 by 24 CSS pixels, with exceptions.
- Consistent Help (3.2.6, Level A). If help is available, it appears in the same relative place on every page that has it.
- Redundant Entry (3.3.7, Level A). Do not make someone type the same information twice in one process.
- Accessible Authentication, Minimum (3.3.8, AA). Do not require a cognitive test, such as transcribing characters or solving a puzzle, as the only way to log in.
One criterion goes the other way. 4.1.1 Parsing is removed, and now reads “Void” in the standard.
If your team has done conformance work to WCAG 2.1 Level AA, that work is not wasted and does not need repeating. These are additions to it.
Adopted is not published. Published is not cited. If you are told the new standard has landed and you must act, ask which step has happened, and which Directive is being talked about. That question sorts the accurate accounts from the rest faster than anything else.
What a presumption of conformity does not tell you
We tested 57 online consumer journeys in Ireland and the Netherlands, attempting each the way a customer using a keyboard or a screen reader would.
Forty stopped us. Thirty-eight of those forty stopped the customer in the middle of the journey, at the moment they say what they want: the dates, the size, the type of cover. Not at the front door, where testing usually happens. The automated checks we ran have told us a control was correctly labelled when it was not.
Figures as of 27 August 2026.
An organisation can hold a well-founded presumption of conformity and still stop seven customers in ten. The standard is the floor. Whether the journey works is a different question, answered by attempting the journey.
Wondering what your journey actually exposes?
Our free assessment shows what a customer using a keyboard or a screen reader meets on your booking, quote or checkout journey, where it stands relative to EAA requirements, and a proportionate next step.
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