EN 301 549 V4.1.1: what the new accessibility standard means for generated documents

ETSI, CEN and CENELEC have published EN 301 549 V4.1.1 (2026-09), the European standard for accessibility of ICT products and services. It was adopted on 24 August 2026 and is developed from V3.2.1 (2021). Two changes matter if you generate or publish documents.

What changed

• WCAG 2.2. Clauses 9 (web), 10 (non-web documents) and 11 (software) are updated to align with the WCAG 2.2 Recommendation.
• European Accessibility Act. The new version was prepared to provide one voluntary means of conforming to Directive (EU) 2019/882. A new clause A.2 and Annex ZB map the requirements to the Act.

Clause 10 covers documents that are not web pages, including downloadable ones: letters, spreadsheets, presentations, e-mails. Typical checks: non-text content (10.1.1.1), info and relationships (10.1.3.1), meaningful sequence (10.1.3.2), non-web document titled (10.2.4.2), language of non-web document (10.3.1.1).

This connects to a date that has already passed. The Act's measures apply from 28 June 2025, and its exemption for office file formats on websites and apps covers only files published before that date (Art. 2(4)(b)). If your service is in scope (for example e-commerce, consumer banking or e-books, Art. 2(2)), the statements, contracts and invoices it publishes for consumers today are not covered by that exemption.

Start with what you already ship

Illustrative example. A one-minute triage of exported PDFs: is the file tagged, does it have a title? It does not prove conformance, but it shows where to look first.

# quick triage of PDFs you publish (poppler-utils)
for f in exports/*.pdf; do
  printf '%s\t' "$f"
  pdfinfo "$f" | grep -E '^(Tagged|Title):' | tr '\n' ' '
  echo
done
# "Tagged: no" or an empty Title -> start the review there

Important. Signed or encrypted does not mean exempt. EN 301 549 says clause 10 also applies to documents protected by digital signatures, encryption, passwords or watermarks when they are presented to the user. And the presumption of conformity with the Act starts only once V4.1.1 is cited in the Official Journal; check that status before you write it into a contract.

Checklist

• ☐ Inventory: which documents your service generates for consumers, in which formats
• ☐ Generator output is tagged, with document title and language set
• ☐ Tables have header rows; images and charts have text alternatives
• ☐ Reading order checked on a sample of real files
• ☐ Templates fixed at the source, not file by file
• ☐ Requirement written into contracts with the vendors who produce your documents

Put it in the RFP

Illustrative example of a requirement line:

M-12 (Must, pass/fail) Accessibility of generated documents.
Documents the solution generates for end users (PDF, DOCX, XLSX,
PPTX) meet EN 301 549 V4.1.1, clause 10 "Non-web documents".
The bidder provides a conformance report and two sample files.

The RFP template is already structured this way: background, scope of work, and Must requirements that are pass/fail. Add one line for document accessibility and every bidder answers it the same way.

Open the RFP template →

Sources: ETSI/CEN/CENELEC EN 301 549 V4.1.1 (2026-09), Foreword and clause 10; Directive (EU) 2019/882 (European Accessibility Act), Art. 2(4)(b), 31(2), Official Journal L 151, 7.6.2019.