Has EN 301 549 been cited for the European Accessibility Act?

Where the standard has actually got to

1. Final draft issued. Done, June 2026.Legal effect: none.
2. Adopted by the national standardisation bodies. Done, 24 August 2026. This is the step being reported as the standard being ready.Legal effect: none.
3. Published by ETSI. Scheduled 3 September 2026. Becomes a published European standard rather than a draft.Legal effect: none.
4. Cited in the Official Journal under Directive (EU) 2019/882. Not reached, no date published.The only step that creates a presumption of conformity.

How we checked

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.

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. Six times, automated tooling 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.