Already Compliant with EN 301 549? What to Reassess for V4.1.0
September 9, 2026
Your organization completed an accessibility audit. Issues were fixed and perhaps you also have an accessibility conformance report.
Does that mean you are covered under EN 301 549 V4.1.0?
Not necessarily.
There are two important reasons:
The standard may have changed. And your product may have changed.
Here is what organizations should consider reassessing.
1. Check Your Existing Audit
Start by checking which versions your previous assessment covered.
Was it based on WCAG 2.1, WCAG 2.2, EN 301 549 V3.2.1, or another standard?
V4.1.0 updates the requirements for web content, non-web documents, and non-web software to align with WCAG 2.2.
An older report may remain useful, but it should not automatically be treated as evidence against requirements that were not assessed.
2. Look Beyond Your Website
EN 301 549 covers more than web accessibility.
Depending on your product ecosystem, your assessment may also need to consider:
- Mobile apps and other software
- Electronic documents
- Hardware
- Communication functionality
- Audiovisual experiences
V4.1.0 also significantly revises requirements around Real-Time Text (RTT) and extends them to total conversation.
The key is to identify what actually applies to your products rather than assuming every requirement applies.
3. Review the New EAA Mapping
For businesses concerned with the European Accessibility Act, V4.1.0 introduces Annex ZB, mapping EN 301 549 to EAA essential requirements.
Clause A.2 also supports evaluation of specific ICT products and services against those requirements.
Compliance teams should therefore review whether their existing evidence adequately addresses the requirements applicable to their products and services.
4. Remember: Your Product Has Probably Changed Too
Even if the standard had not changed, your digital product may have.
New features, redesigned journeys, third-party integrations, new components, app releases, and new documents can all introduce accessibility barriers.
Therefore, reassessment should consider both:
Changes in the standard + Changes in the product
A Simple Reassessment Approach
You don’t necessarily need to start your accessibility programme again from zero.
Instead:
Review existing evidence → Identify relevant changes → Determine applicable requirements → Conduct targeted reassessment → Remediate → Retest → Update evidence
Three Questions to Ask Internally
Before your next compliance review, ask:
- Which versions of WCAG and EN 301 549 were we last assessed against?
- What has changed in our products since then?
- Do we have current evidence demonstrating conformity with the requirements applicable to us?
If these questions cannot be answered confidently, it may be time for a reassessment.
Already completed an EN 301 549 or WCAG audit? SaralX can help identify what has changed and where reassessment is actually required—without unnecessarily starting the entire exercise from scratch.