The European Union has officially updated its digital accessibility standard EN 301 549 to adopt WCAG 2.2. If you're a UK developer or agency working with European clients, this affects your projects right now.
What's Changed
EN 301 549 is the technical standard that underpins the European Accessibility Act (EAA). Until this update, it referenced WCAG 2.1. Now it requires WCAG 2.2 compliance, bringing nine new success criteria into scope for EU regulatory requirements.
For UK agencies serving European markets, this isn't optional. If your clients sell products or services to EU customers, their digital properties need to meet this standard.
The New WCAG 2.2 Success Criteria
WCAG 2.2 added nine success criteria. Here's what they mean in practice:
Focus Not Obscured (Minimum) - 2.4.11 (Level AA)
When a user tabs to an element, it can't be completely hidden behind sticky headers, cookie banners, or chat widgets. At least part of the focused element must be visible.
Fix: Check your sticky navigation and floating elements. If they cover focused content, add scroll padding or adjust z-index behaviour.
Focus Not Obscured (Enhanced) - 2.4.12 (Level AAA)
The stricter version: the focused element must be fully visible, not just partially.
Focus Appearance - 2.4.13 (Level AAA)
Focus indicators need a minimum size (at least 2px thick outline or equivalent area) and sufficient contrast. This one's AAA, so not required for EN 301 549 compliance, but worth implementing anyway.
Dragging Movements - 2.5.7 (Level AA)
Any function that uses dragging (sliders, drag-and-drop interfaces, map panning) must have a single-pointer alternative. Users who can't perform drag gestures need another way to achieve the same result.
Fix: Add increment/decrement buttons to sliders. Provide tap-to-place alternatives for drag-and-drop. Include zoom buttons alongside pinch-to-zoom.
Target Size (Minimum) - 2.5.8 (Level AA)
Interactive targets need to be at least 24x24 CSS pixels, OR have sufficient spacing from other targets. There are exceptions for inline links and browser-default controls.
Fix: Audit your button and link sizes. Pay particular attention to icon buttons, close buttons, and form controls. The 24px minimum is smaller than the AAA requirement (44px) but still catches a lot of undersized touch targets.
Consistent Help - 3.2.6 (Level A)
If you provide help mechanisms (contact links, chat widgets, FAQ links), they need to appear in the same relative order across pages.
Fix: Keep your help links in a consistent footer or header position. Don't move your contact page link around between pages.
Redundant Entry - 3.3.7 (Level A)
Don't make users re-enter information they've already provided in the same session. Auto-populate or let them select from previous entries.
Fix: If a user enters their address in step 1 of a form, pre-fill it in step 3. Offer "same as billing address" checkboxes.
Accessible Authentication (Minimum) - 3.3.8 (Level AA)
Cognitive function tests (like remembering a password or solving a puzzle) can't be required for login unless you provide an alternative. Alternatives include password managers, copy-paste functionality, or biometric options.
Fix: Don't block paste in password fields. Support password managers. If you use CAPTCHAs, provide an alternative method.
Accessible Authentication (Enhanced) - 3.3.9 (Level AAA)
The stricter version removes some exceptions. AAA level, so not required for compliance.
What This Means for UK Projects
Post-Brexit, the UK isn't bound by EN 301 549. But if your clients:
- Sell products or services to EU customers
- Have offices or operations in EU countries
- Work with EU public sector organisations
...they need to meet this standard. The EAA has been enforceable since June 2025, and regulators are starting to pay attention.
Even for UK-only projects, WCAG 2.2 is the current best practice. The UK's own accessibility regulations haven't updated to require 2.2 yet, but they likely will. Getting ahead of this now saves retrofit work later.
Practical Next Steps
- Audit existing projects for the new Level A and AA criteria, particularly target sizes and dragging alternatives
- Update your component libraries to meet 2.5.8 target size requirements by default
- Check sticky elements aren't obscuring focused content
- Review authentication flows for cognitive barriers
The new criteria aren't difficult to meet if you design for them from the start. Retrofitting is harder.
WCAGCheck scans your website for WCAG compliance issues and tells you exactly what to fix. Try it free at wcagcheck.co.uk