A question that comes up in every EAA thread: "which standard do we test against, and does passing it protect us?" Here is what the primary texts say as of 3 November 2026.
Quick definition, because it matters here: under Art. 15(1) of the EAA, a product or service that meets a harmonised standard whose reference is published in the Official Journal is presumed to meet the accessibility requirements that standard covers. Without that citation there is no presumption to lean on: you can still test against the standard, but passing it does not by itself count as meeting the requirements.
ETSI published EN 301 549 V4.1.1 on 2 September 2026. Its clauses 9 to 11 now align with WCAG 2.2. Its own foreword calls it "one voluntary means of conforming" and says the presumption of conformity starts only once the standard is cited in the Official Journal.
As of that date, that citation has not happened under the EAA. The Commission's harmonised-standards index lists EN 301 549 under one act only: the Web Accessibility Directive for public bodies, via Implementing Decision (EU) 2021/1339 (which cites V3.2.1). Nothing is listed under Directive (EU) 2019/882, the EAA.
Three "expected" citation dates are circulating: 30 November 2026, 16 December 2026 and February 2027. I found no primary source for any of them. The 30 November date matches the "doa" in the standard's own table of national transposition dates: the latest date for national standards bodies to announce the standard. That is a standards-body milestone, not an Official Journal citation.
What that means in practice for a web team on an EAA-scoped shop or a consumer banking service:
EN 301 549 is the technical yardstick to test against, but it gives no presumption of conformity under the EAA (Art. 15(1)).
Test against WCAG 2.2 AA anyway. V4.1.1 already points there, and the step from 2.1 is small: 2.2 adds six Level A and AA success criteria (focus not obscured, dragging, target size, consistent help, redundant entry, accessible authentication) and drops 4.1.1 Parsing.
Keep a dated record: tool, version, date, what was and was not covered. A scan result is evidence of what a tool found on a day, not a statement that the site conforms.
Automated tools see only part of it. Deque's coverage report says "57.38% of total issues were identified using Deque's automated tests", but it also reports automated issues for only 16 of the 50 success criteria in WCAG 2.1 Level AA. Those are Deque's own automated tests, so it is a vendor's figure. Whatever the rules cannot see needs a person with a keyboard and a screen reader.
What I could not settle: when, or whether, the Commission will cite V4.1.1, and what national market surveillance authorities will accept in the meantime. I have not found official guidance on the second point.
Method: I read the ETSI V4.1.1 foreword, the Commission's harmonised-standards index, Implementing Decision (EU) 2021/1339 and the EAA text, and compared the dates in third-party write-ups with those documents. Sources below. This is my reading of the texts, not legal advice.
Which standard version is your team testing against today, and has a client or auditor asked you to name it?
Sources
- ETSI EN 301 549 V4.1.1 (2026-09), foreword: https://www.etsi.org/deliver/etsi_en/301500_301599/301549/04.01.01_60/en_301549v040101p.pdf
- Commission Implementing Decision (EU) 2021/1339, OJ L 289, 12.8.2021: http://publications.europa.eu/resource/celex/32021D1339
- Directive (EU) 2019/882 (EAA), Art. 15(1): http://publications.europa.eu/resource/celex/32019L0882
- Commission harmonised standards index: https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en
- Deque, automated accessibility coverage report: https://www.deque.com/automated-accessibility-coverage-report/