The European accessibility standard EN 301 549 has been updated, introducing the new WCAG 2.2 success criteria as well as several other changes. This also brings the adoption of the new requirements into Finnish accessibility legislation one step closer. The changes will affect both public sector organisations and private sector services covered by the European Accessibility Act.
The update to EN 301 549 goes beyond simply moving from one version of WCAG to another. The standard has also been revised to support the requirements of the European Accessibility Act. Rather than covering every change introduced in the updated standard, this article highlights some of the key considerations for digital services that designers and developers should be aware of.
For web services, the most significant change is the adoption of WCAG 2.2. It introduces six new Level A and AA success criteria to the standard and removes the obsolete Success Criterion 4.1.1 Parsing.
What to check in your digital service:
- Sticky headers, footers and cookie banners: Make sure that areas that remain fixed at the top or bottom of the page, or otherwise float above the content, do not obscure elements when they receive keyboard focus. Read more: 2.4.11 Focus Not Obscured (Minimum) (AA)
- Does your service include drag-and-drop functionality? Make sure the same action can also be completed using another method available with a pointing device, such as clicking a button. Read more: 2.5.7 Dragging Movements (AA)
- Size and spacing of interactive elements: Check that small buttons and other clickable targets in particular are at least 24 × 24 CSS pixels, or that there is sufficient space between them and adjacent targets. Read more: 2.5.8 Target Size (Minimum) (AA)
- Help mechanisms: If customer service contact details, a chatbot or another help mechanism appears across multiple pages of your service, make sure users can find it in a consistent location. Read more: 3.2.6 Consistent Help (A)
- Does the user have to enter the same information twice during the same process? Make sure information already provided is either automatically populated or available for the user to select without having to enter it again. Read more: 3.3.7 Redundant Entry (A)
- Login and authentication: Check whether users can copy and paste information into login fields, for example from a password manager. Also review how verification codes and CAPTCHA solutions work. As a rule, authentication should not require users to complete a cognitive function test, although recognising common objects in images is one of the exceptions permitted under the Level AA criterion. Read more: 3.3.8 Accessible Authentication (Minimum) (AA)
- Users’ accessibility preferences: A web page should not, unless strictly necessary, prevent the browser from following the user’s accessibility preferences or override the accessibility settings of the platform. These may include settings related to contrast, text size and pointer size. Read more: EN 301 549 v4.1.1, 9.7 User preferences for web pages (pdf)
- Real-time bidirectional communication: If your service includes calls, video calls or other real-time communication features, review the updated requirements of the standard. Read more: EN 301 549 v4.1.1, 6 ICT supporting real-time bidirectional communication (pdf)
Where to start?
The new accessibility requirements can improve both the quality of your service and the user experience for a broader range of people. This makes it a good time to update the guidelines and checklists used by designers, developers and testers.
Existing services should already be reviewed against the new requirements to identify any gaps. If you are planning a new service, the requirements should be considered from the very beginning, starting with requirements definition.
No legislative amendment is required in Finland
Once the reference to EN 301 549 v4.1.1 is published in the Official Journal of the European Union as a harmonised standard, the technical accessibility requirements under Finland’s Act on the Provision of Digital Services will also be updated to reflect the new standard, taking into account any applicable transition periods. According to some sources, such as universaldesign.ie, this is expected to take place in December 2026. Finland’s Act on the Provision of Digital Services does not need to be amended separately for this purpose, as the legislation does not refer to a specific version of EN 301 549.
The transition to the new version of the standard is therefore relatively straightforward in Finland. The situation is not the same in every EU Member State, as national legislation may require separate amendments before the new requirements become applicable nationally.
Need help preparing for the new requirements?
The EN 301 549 update means organisations need to review and update their accessibility guidelines, ensure that existing services meet the new requirements, and make sure their teams have the necessary knowledge and skills.
Gofore’s accessibility experts work with organisations of different sizes across a wide range of sectors, from public administration to financial services and healthcare. We can support you with individual accessibility audits as well as broader preparations for the upcoming changes, including:
- Identifying where to start when time or resources are limited
- Training design and development teams on the new requirements
- Updating accessibility checklists, guidelines and processes
Our accessibility experts are here to help you prepare for the changes
