Short answer. For Australian Government websites and digital services, the requirement is WCAG 2.2 Level AA. The Digital Service Standard and the Digital Inclusion Standard require the latest version of WCAG, which is 2.2. When agencies buy ICT, AS EN 301 549:2024 also applies and extends the requirements to documents, software and hardware. Its reference to WCAG 2.1 is a lag in the standard, not a lower bar.
What AS EN 301 549 is#
AS EN 301 549 sets accessibility requirements for information and communications technology. Standards Australia publishes it as a direct adoption of the European standard EN 301 549.
The current edition is AS EN 301 549:2024. It replaces the 2016 and 2020 editions and adopts the European version published in 2020 (V3.1.1).
Europe published a new version, EN 301 549 V4.1.1, on 2 September 2026. It names WCAG 2.2. Australia has not adopted it yet.
It covers far more than websites:
- web content
- non-web documents, such as PDFs and Word files
- software and apps
- technology with two-way voice or video
- hardware
- documentation and support services
For web content, it uses the WCAG Level A and AA success criteria. The other clauses apply similar requirements to everything else a supplier delivers.
Where each standard applies#
Since November 2025, the Commonwealth Procurement Rules require tenderers to show they can meet the standards named in a procurement, Australian or international, and agencies can ask for evidence such as certifications. The Australian Human Rights Commission notes that AS EN 301 549:2024 applies to most ICT goods and services bought by government.
Agencies carry their own obligations too. The Digital Service Standard and the Digital Inclusion Standard both require the latest version of WCAG. Criterion 4 of the Digital Inclusion Standard asks agencies directly: have new procurements and contract renewals considered accessibility?
So your agency has to show that accessibility was considered, and your suppliers' evidence is how you show it.
State and territory governments have their own digital standards, and most point to WCAG, though some still name older versions. Always check what the specific tender asks for.
Why AS EN 301 549 still says WCAG 2.1#
AS EN 301 549:2024 adopts the European standard as it stood in 2020. The W3C published WCAG 2.2 in October 2023, so the Australian edition still names WCAG 2.1.
That does not lower the bar for federal agencies. The digital standards already require the latest version of WCAG. The Australian Human Rights Commission says organisations should conform with WCAG 2.2 Level AA at a minimum, and use it in place of 2.1 where AS EN 301 549 applies.
The lag is closing. On 2 September 2026, Europe published EN 301 549 V4.1.1, which moves its web, document and software clauses to WCAG 2.2 Level AA. Formal citation in the EU is expected late in 2026. When Standards Australia adopts it, the Australian standard will name WCAG 2.2 too.
The practical effect: for a federal website or digital service, evidence that only covers WCAG 2.1 does not meet the requirement.
What changed between WCAG 2.1 and 2.2#
WCAG 2.2 adds nine success criteria and removes one, 4.1.1 Parsing, leaving 86 in total. Six of the new criteria are Level A or AA, so they count in a standard AA audit:
- 2.4.11 Focus Not Obscured (Minimum), AA: sticky headers, cookie banners and chat widgets must not hide the element that has keyboard focus.
- 2.5.7 Dragging Movements, AA: anything done by dragging, such as sliders or reordering, also works with a single click or tap.
- 2.5.8 Target Size (Minimum), AA: buttons and links are at least 24 by 24 CSS pixels, or have enough space around them.
- 3.2.6 Consistent Help, A: help options such as contact details or chat appear in the same place across pages.
- 3.3.7 Redundant Entry, A: people are not asked to re-enter information they already gave in the same process.
- 3.3.8 Accessible Authentication (Minimum), AA: logins do not depend on a memory or puzzle test unless there is an alternative, such as allowing paste and password managers.
Most of these live in components: buttons, headers, forms and login screens. Fix the component and every page that uses it is fixed too. Our article on component accessibility explains what to ask your website builder.
What agencies should do now#
- Ask for WCAG 2.2 Level AA, not 2.1. Put it in every approach to market, contract and renewal. Federal digital standards already require it, and the next AS EN 301 549 is likely to name it.
- Ask for evidence mapped to AS EN 301 549. Cover documents and software as well as web pages.
- Check the date and version on every report. Each one should state the WCAG version, the standard edition and the test date.
- Re-test before contract renewals. Renewals are a named checkpoint in the Digital Inclusion Standard.
- Watch for the Australian update. Standards Australia adopting EN 301 549 V4.1.1 will make WCAG 2.2 explicit.
For exactly what to ask suppliers to provide, see our article on accessibility evidence in government procurement.
Frequently asked questions#
Is AS EN 301 549 mandatory?#
Standards Australia publishes it as a voluntary standard. It becomes binding when a procurement or contract names it. Under the Commonwealth Procurement Rules, tenderers must then show they can meet it.
Should we accept WCAG 2.1 evidence from a supplier?#
For a federal website or digital service, no. The digital standards require the latest version of WCAG, which is 2.2, and WCAG 2.1 evidence leaves the six new Level A and AA criteria untested. Ask for WCAG 2.2 AA, which also satisfies AS EN 301 549 for web content.
What is the difference between WCAG and AS EN 301 549?#
WCAG covers web content. AS EN 301 549 includes WCAG for web content and adds requirements for documents, software, hardware and support services.
Do these standards apply to our suppliers as well as our agency?#
Yes. Your agency carries the obligation under the Digital Service Standard and Digital Inclusion Standard, and AS EN 301 549 applies to the ICT you buy. Suppliers need to show they meet the standards you name. Separately, the Disability Discrimination Act applies to anyone providing goods or services.
Talk to us#
Planning a procurement, a contract renewal or a Digital Inclusion Standard report? Book a free 15-minute call. We will tell you what evidence to ask for and whether what you hold is current.
