Changes in EN 301549 for public sector websites

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Recently, the European standard on accessibility requirements for ICT products and services received an update. What does this update mean for public sector websites?

About EN 301549

But first, what is EN 301549 actually? In summary, it is a European standard that contains accessibility requirements for ICT products and services. These requirements are written in so called clauses. For websites, it refers to the Web Content Accessibility Guidelines (WCAG), but it also has extra requirements for accessibility. Some examples are requirements for two-way communication, media players, and user preferences.

In the annex of the standard, there is a table that lists the relevant clauses for the Web Accessibility Directive (WAD). This directive is transposed into national legislation, such as DOS-lagen in Sweden and the Besluit digitale toegankelijkheid overheid in the Netherlands. This national legislation, in turn, is what websites of public organisations need to comply to. The table in this annex is therefore also what web accessibility auditors use to audit a website.

Changes in versions of EN 301549

For a couple of years, we’ve been using version 3.2.1 of EN 301549 as the current standard. Meanwhile, some of the most knowledgable people about standardisation worked on a new version of this standard.

In September 2026, version 4.1.1 was published and is due to become part of the legal basis soon. Please note that at the moment of writing, version 3.2.1 is still the applicable version in legislation. Version 4.1.1 becomes applicable when it is cited in the Official Journal of the EU, which is expected to happen in November 2026.

Changes in a nutshell

The changes in version 4.1.1, compared to version 3.2.1 are, in a nutshell:

  • Instead of WCAG version 2.1, the standard now refers to WCAG version 2.2, which contains more success criteria. Since most accessibility auditors already audit websites according to WCAG 2.2, this should not mean a big difference in practice.
  • Clause 11.7 on user preferences is now divided into three different clauses for websites (9.7), documents (10.7), and apps (11.7). The main difference here, is that now websites and documents are not allowed to block or overwrite user preferences. Apps and other software need to follow the user preferences. I think these clauses still provide room for discussion, which I will keep an eye on in the coming period.
  • Clause 6 about two-way communication has been expanded with more requirements.
  • In clause 7, the word “captions” has been altered to “subtitles”.
  • Requirements for editing tools have been moved from clause 11 to 5.
  • In clause 12, requirements about electronic program guides (EPG) have been added.

Comparison table of version 3.2.1 and 4.1.1

The table below shows my understanding of the changes in the relevant clauses for websites of public sector organisations. Please note that this table only applies to websites, not to documents or apps. However, most of these changes also apply to documents and apps.

Please note that for this table, I only looked at the titles and numbers of the clauses. It is by no means a representation of changes in the contents of the clauses. When the table mentions “No change”, it means no change in the title and numbering. Please read the clauses themselves to get an understanding of their meaning.

Version 4.1.1Version 3.2.1Changes
Annex A, table ZA.1Annex A, table A.1Change in title
5.2 Activation of accessibility features5.2 Activation of accessibility featuresNo change
5.3 Biometrics5.3 BiometricsNo change
5.4 Preservation of accessibility information during conversion5.4 Preservation of accessibility information during conversionNo change
5.6.1 Tactile or auditory status–New
5.6.2 Visual status–New
5.7 Key repeat–New
5.8 Double-strike key acceptance–New
5.9 Simultaneous user actions–New
5.10.1 Content technology11.8.1 Content technologyChange in clause numbering
5.10.2 Accessible content creation11.8.2 Accessible content creationChange in clause numbering
5.10.3 Preservation of accessibility information in transformations11.8.3 Preservation of accessibility information in transformationsChange in clause numbering
5.10.4 Repair assistance11.8.4 Repair assistanceChange in clause numbering
5.10.5 Templates11.8.5 TemplatesChange in clause numbering
6.0.2 Communication client–New
6.0.3 Communication system–New
6.0.4 System connecting to another communication system–New
6.0.5 System with roaming visiting client–New
6.0.6 Client in emergency communications–New
6.0.7 Emergency communications–New
6.0.8 System with roaming visiting client in an emergency–New
6.0.9 System with client in emergency visiting another country–New
6.1.1 Voice communication interoperability–New
6.1.2 Audio bandwidth for capture and presentation for voice communication6.1 Audio bandwidth for speechChange in title and clause numbering
6.2.1.1 RTT functionality6.2.1.1 RTT communicationChange in title
6.2.1.2 Concurrent voice and RTT6.2.1.2 Concurrent voice and textChange in title
6.2.1.3 Single user operations–New
6.2.2.1 Distinguishable display6.2.2.1 Visually distinguishable displayChange in title
6.2.2.2 Active communicator indication6.2.2.2 Programmatically determinable send and receive directionChange in title
6.2.2.3 Indication of audio with RTT6.2.2.3 Speaker identificationChange in title
6.2.2.4 Presentation of relative time order of text6.2.2.4 Visual indication of Audio with RTTChange in title
6.2.2.5 Review of RTT communication contents–New
6.2.3 DTMF touch-tone generation during RTT operations6.2.3 InteroperabilityChange in title
6.2.4 RTT responsiveness6.2.4 RTT responsivenessNo change
6.2.5 Adding and erasing of RTT input–New
6.2.6 Processing rate of RTT–New
6.2.7 Character representation–New
6.2.8 RTT input methods–New
6.2.9 RTT media establishment and use–New
6.2.10 RTT interoperability–New
6.3 Caller ID6.3 Caller IDNo change
6.4 Alternatives to voice-based services6.4 Alternatives to voice-based servicesNo change
6.5.2 Resolution6.5.2 ResolutionNo change
6.5.3 Frame rate6.5.3 Frame rateNo change
6.5.4 Synchronization between audio and video6.5.4 Synchronization between audio and videoNo change
6.5.5 Indicator of audio with video6.5.5 Visual indicator of audio with videoChange in title
6.5.6 Indication of all active communication participants6.5.6 Speaker identification with video (sign language) communicationChange in title
6.7.1 Total conversation provision–New
6.7.2 Total conversation interoperability–New
7.1.1 Subtitle playback7.1.1 Captioning playbackChange in title
7.1.2 Subtitle synchronization7.1.2 Captioning synchronizationChange in title
7.1.3 Preservation of subtitles7.1.3 Preservation of captioningChange in title
7.1.4 Subtitle characteristics7.1.4 Captions characteristicsChange in title
7.1.5 Spoken subtitles7.1.5 Spoken subtitlesNo change
7.2.1 Audio description playback7.2.1 Audio description playbackNo change
7.2.2 Audio description synchronization7.2.2 Audio description synchronizationNo change
7.2.3 Preservation of audio description7.2.3 Preservation of audio descriptionNo change
7.3 User control of audiovisual accessibility features7.3 User controls for captions and audio descriptionChange in title
9.1.1.1 – 9.2.4.7 WCAG success criteria9.1.1.1 – 9.2.4.7 WCAG success criteriaNo change
9.2.4.11 Focus not obscured (minimum)–New
9.2.5.1 – 9.2.5.4 WCAG success criteria9.2.5.1 – 9.2.5.4 WCAG success criteriaNo change
9.2.5.7 Dragging movements–New
9.2.5.8 Target size (minimum)–New
9.3.1.1 – 9.3.2.4 WCAG success criteria9.3.1.1 – 9.3.2.4 WCAG success criteriaNo change
9.3.2.6 Consistent help–New
9.3.3.1 – 9.3.3.4 WCAG success criteria9.3.3.1 – 9.3.3.4 WCAG success criteriaNo change
9.3.3.7 Redundant entry–New
9.3.3.8 Accessible authentication (minimum)–New
–9.4.1.1 ParsingDeleted
9.4.1.2 – 9.4.1.3 WCAG success criteria9.4.1.2 – 9.4.1.3 WCAG success criteriaNo change
9.6 WCAG conformance requirements9.6 WCAG conformance requirementsNo change
–10.1.1.1 – 10.4.1.3Deleted
9.7 User preferences for web pages11.7 User preferencesChange in title and clause numbering
12.1 Accessible information about products12.1.2 Accessible documentationChange in title and clause numbering
12.2 Accessible information about services–New
12.3 Accessibility and compatibility features12.1.1 Accessibility and compatibility featuresChange in clause numbering
–12.2.2 Information on accessibilityDeleted
–12.2.3 Effective communicationDeleted
–12.2.4 Accessible documentationDeleted
12.4 Electronic program guides–New
12.5 Electronic program guide display–New
13.1.2.2 Use of the primary user destination adress in relayed communications–New
13.1.2.3 Conveying of caller identifier in relayed communications for primary relay users–New
13.1.2.4 Relay service invocation decision in outgoing communications–New
13.1.2.5 Relay service invocation decision in incoming communications–New
13.1.2.6 Relay service support requested by the primary user for emergency communications–New
13.1.3.1 Relaying action in relay service communication–New
13.1.3.2 Media handling in relay service communication–New
13.1.3.3 Relay service support in ICT based conferences–New
13.1.3.4 Relay service support during emergency communications initiated by the PSAP–New

I hope this overview helps you preparing for the change. Do you see any errors or unclarities? Please let me know.

Featured image by Vitaly Gariev on Unsplash.

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