WCAG 2.2 AA and EN 301 549: which one applies to an online shop

WCAG and EN 301 549 are not two competing standards. EN 301 549 is the European standard for the accessibility of ICT products and services, and for web pages it uses the success criteria of WCAG, the W3C’s Web Content Accessibility Guidelines. So the practical questions are which WCAG version a requirement names, and which version of EN 301 549 EU law cites.

The table compares the four documents this guide covers. The sections below explain each one, with links to the W3C, ETSI and EUR-Lex. Which law applies to a particular shop, and with which standard, is a legal assessment that this guide does not make.

WCAG, the Web Content Accessibility Guidelines, is the standard for accessible web content published by the World Wide Web Consortium (W3C). The W3C’s Accessibility Guidelines Working Group develops it, and WCAG 2.2, the version this guide is about, is a W3C Recommendation.

WCAG 2.2 is built in layers (WCAG 2.2, layers of guidance): four principles at the top, 13 guidelines under them, and testable success criteria under the guidelines. Each success criterion has one of three levels: A (the lowest), AA and AAA (the highest). “WCAG 2.2 AA” is short for conformance to WCAG 2.2 at Level AA. At its core, that means a page satisfies every success criterion at Levels A and AA; the section on Level AA below sets out the full conformance requirements.

WCAG 2.2 adds six success criteria at Levels A and AA to those of WCAG 2.1 and removes one, 4.1.1 Parsing. Every other success criterion at those levels keeps its number and level.

WCAG 2.1 became a W3C Recommendation on 5 June 2018, and the W3C published updated editions on 21 September 2023, 12 December 2024 and 6 May 2025 (WCAG 2.1 publication history). WCAG 2.2 became a W3C Recommendation on 5 October 2023. On 12 December 2024 the W3C republished it with editorial corrections and changes to four definitions; no success criterion was added or removed (WCAG 2.2 publication history).

WCAG 2.1 has 50 success criteria at Levels A and AA: 30 at Level A and 20 at Level AA. WCAG 2.2 has 55 success criteria at Levels A and AA: 31 at Level A and 24 at Level AA. Take the 50 of WCAG 2.1, remove 4.1.1 and add the six new criteria, and the result is the 55 of WCAG 2.2. Validiscan counted these numbers in each Recommendation.

The six new success criteria at Levels A and AA are listed in WCAG 2.2’s section on new features. WCAG 2.2 adds three more at Level AAA.

Three of the six concern parts of an online shop directly. Redundant Entry applies within one process, and WCAG’s own example of a process is an online store’s pages through to checkout (see below). Accessible Authentication (Minimum) applies to every step of a log-in, such as the log-in to a customer account; the W3C names support for password managers and copy and paste as examples of a mechanism that helps. Target Size (Minimum) applies to the targets a visitor operates with a pointer, such as buttons and links.

WCAG 2.2 marks 4.1.1 Parsing as obsolete and removed. The W3C’s note says that the criterion was adopted for problems assistive technology had when parsing HTML directly, that assistive technology no longer needs to do that, and that the criterion “no longer has utility” (WCAG 2.2, 4.1.1 Parsing).

Yes, according to the W3C, with one note on 4.1.1 Parsing (below). WCAG 2.2 states: “Content that conforms to WCAG 2.2 also conforms to WCAG 2.0 and WCAG 2.1.”

WCAG 2.2 does not replace the earlier versions. WCAG 2.2 states that its publication “does not deprecate or supersede WCAG 2.0 or WCAG 2.1”, which remain W3C Recommendations. The Accessibility Guidelines Working Group recommends that sites adopt WCAG 2.2 as their new conformance target, “even if formal obligations mention previous versions” (WCAG 2.2, new features).

One note concerns 4.1.1 Parsing. Authors who are required by policy to conform with WCAG 2.0 or 2.1 “may need to continue to test and report 4.1.1”, WCAG 2.2 says (comparison with WCAG 2.1). WCAG 2.1 itself, in its editions since 21 September 2023, carries a note on that criterion: it “should be considered as always satisfied for any content using HTML or XML” (WCAG 2.1, 4.1.1 Parsing).

A web page conforms to WCAG 2.2 at Level AA when it satisfies every Level A and Level AA success criterion, or when a conforming alternate version at Level AA is provided. That is the first of five conformance requirements, and a page has to meet all five: the conformance level, full pages, complete processes, only accessibility-supported ways of using technologies, and non-interference (WCAG 2.2, conformance requirements).

Two of the requirements are worth knowing for a shop:

• Full pages. Conformance is for full web pages only, and “cannot be achieved if part of a web page is excluded”. A full page includes each variation that the page presents automatically for different screen sizes, so the phone layout of a responsive shop page has to conform as well, or have a conforming alternate version (WCAG 2.2, full pages).
• Complete processes. When a page is one step in a process, every page in the process has to conform. WCAG’s own example is a shop: “An online store has a series of pages that are used to select and purchase products. All pages in the series from start to finish (checkout) conform in order for any page that is part of the process to conform.” (WCAG 2.2, complete processes)

Level AAA is the highest level. WCAG does not recommend requiring it as a general policy for entire sites, “because it is not possible to satisfy all Level AAA success criteria for some content” (WCAG 2.2, conformance level). A formal conformance claim is optional under WCAG (WCAG 2.2, conformance claims).

EN 301 549 is a Harmonised European Standard titled “Accessibility requirements for ICT products and services”. It covers ICT in general, not only websites; its clause 9 holds the requirements for the web. Version 3.2.1, dated March 2021, was produced by ETSI’s Technical Committee Human Factors and the eAccessibility Joint Working Group of CEN, CENELEC and ETSI, in response to the European Commission’s standardisation request M/554 (EN 301 549 V3.2.1).

For web pages, EN 301 549 V3.2.1 states each requirement as a WCAG 2.1 success criterion, and it sums up the relation in one sentence: “Conformance with W3C Web Content Accessibility Guidelines (WCAG 2.1) Level AA is equivalent to conforming with all of clauses 9.1 to 9.4 and the conformance requirements of clause 9.6 of the present document.” The WCAG 2.1 Level AAA criteria are in clause 9.5, which is informative (EN 301 549 V3.2.1).

EN 301 549 is more than WCAG. The European Commission notes that V3.2.1 “includes requirements that are not part of WCAG 2.1”, and that in V3.2.1 WCAG 2.1 also applies to documents downloaded from the web (European Commission, web accessibility standards).

EN 301 549 V4.1.1, which ETSI published in September 2026, moves the standard from WCAG 2.1 to WCAG 2.2. Its normative reference for WCAG is the W3C Recommendation of 12 December 2024, listed together with ISO/IEC 40500:2025, and ETSI states that the requirements in clauses 9, 10 and 11 (web, non-web documents and software) “have all been updated to align with the WCAG 2.2 recommendation” (EN 301 549 V4.1.1).

ETSI states that V4.1.1 was developed in response to the Commission’s standardisation request M/587, and that it has two annexes relating the standard to EU law: Annex ZA for the Web Accessibility Directive (EU) 2016/2102, an update of Annex A of the previous version, and a new Annex ZB for the European Accessibility Act, Directive (EU) 2019/882 (EN 301 549 V4.1.1). The request M/587 concerns the accessibility requirements of products and services under the European Accessibility Act (Rolling Plan for ICT Standardisation 2026).

Publication by ETSI is one step. A reference in the Official Journal is another, and the next section covers it.

The Official Journal of the European Union cites EN 301 549 V3.2.1, and it does so under the Web Accessibility Directive (EU) 2016/2102, which concerns the websites and mobile applications of public sector bodies. As of 6 October 2026, Validiscan found no reference in the Official Journal to EN 301 549 V4.1.1, and none to a harmonised standard under the European Accessibility Act.

The citation of V3.2.1 is Commission Implementing Decision (EU) 2021/1339 of 11 August 2021, published in the Official Journal L 289 of 12 August 2021, pages 53 to 55. It amends Implementing Decision (EU) 2018/2048 on the harmonised standard for websites and mobile applications, and provides for the withdrawal of the reference of the earlier version, V2.1.2 of August 2018.

Under the Web Accessibility Directive, such a citation gives a presumption of conformity. As Implementing Decision (EU) 2018/2048 sets out, Article 6(1) of that Directive provides that content of websites and mobile applications that conforms to a harmonised standard cited in the Official Journal is presumed to meet the accessibility requirements of Article 4 of that Directive that the standard covers.

The European Accessibility Act (EAA) has its own rule. Under Article 15 of Directive (EU) 2019/882, products and services that conform to harmonised standards whose references are published in the Official Journal “shall be presumed to be in conformity with the accessibility requirements of this Directive in so far as those standards or parts thereof cover those requirements”. Where no such reference is published, the Commission may, under conditions the article sets out, adopt technical specifications by implementing act. The Commission’s standardisation request for the EAA, M/587, was published on 14 September 2022, and the revision of EN 301 549 is one of the activities under it (Rolling Plan for ICT Standardisation 2026).

For the Web Accessibility Directive, the European Commission describes the order of events: “first, the standard has to be updated, and then it needs to be referenced in the Official Journal” (European Commission, web accessibility standards).

The European Accessibility Act covers e-commerce services provided to consumers, and Member States apply its measures from 28 June 2025. Microenterprises that provide services (fewer than 10 persons employed, and an annual turnover or annual balance sheet total of no more than EUR 2 million) are exempt from its accessibility requirements for services. The guide to the European Accessibility Act for online shops sets out its scope, definitions and requirements, and the guide to the BFSG for online shops covers Germany’s law.

Put together, the facts in this guide are these:

• Under the EAA, conformity to a harmonised standard gives a presumption of conformity with the accessibility requirements the standard covers, once the standard’s reference is published in the Official Journal. As of 6 October 2026, Validiscan found no such reference under the EAA.
• The version of EN 301 549 that the Official Journal cites, V3.2.1, is cited under the Web Accessibility Directive and uses WCAG 2.1 Level AA.
• The newest version as of 6 October 2026, EN 301 549 V4.1.1, is aligned with WCAG 2.2.
• The W3C states that content that conforms to WCAG 2.2 also conforms to WCAG 2.1, and its working group recommends WCAG 2.2 as the conformance target even where formal obligations mention earlier versions.

Whether the EAA applies to a particular shop, whether the microenterprise exemption covers it, and which standard a court or an authority would apply to it are legal questions for a lawyer or the competent national authority. This guide does not answer them.

Validiscan works to WCAG 2.2 AA and reports against both WCAG 2.1 AA and WCAG 2.2 AA. Its scans check a shop’s pages with automated rules mapped to WCAG success criteria, and it delivers fixes as changes to the shop’s own code: a pull request, an unpublished copy of a Shopify theme, or a patch bundle.

The Remediation Evidence Package gives each success criterion at Levels A and AA one result from one evaluation and shows it in two tables: one for WCAG 2.1 AA, the version EN 301 549 V3.2.1 uses, and one for WCAG 2.2 AA, the version V4.1.1 is aligned with. A criterion with an item on the manual checklist and no manual result yet is shown as not evaluated, and so is a criterion that nothing tests; a criterion that rules test and that has no checklist item is shown as supported when the rules find no failure. In the WCAG 2.1 AA table, 4.1.1 Parsing is shown as supported without a test, following the note in WCAG 2.1 that it should be considered as always satisfied for content using HTML or XML. The package’s scope statement reads: “Conformance with WCAG 2.1 AA and WCAG 2.2 AA success criteria as evaluated on the listed pages and dates.” It also says: “This package is evidence of an evaluation and of remediation work. It is not a certificate and does not state legal compliance.” Validiscan does not assess whether a shop meets a law.

The criteria matrix lists every WCAG 2.2 success criterion at Levels A and AA with the rules that test it, where there are any, and shows what automated checks cover and what needs a person. The guide on what automated accessibility testing can and cannot prove explains why some criteria need a person.