comparison
WCAG 2.2 vs EAA
WCAG 2.2 (Web Content Accessibility Guidelines 2.2, Global (referenced by most national accessibility laws), 2023) and EAA (European Accessibility Act, European Union (all 27 member states), 2019) are two of the most-referenced accessibility frameworks in digital compliance. This guide compares them side by side — jurisdiction, scope, conformance approach, penalties, and how a single audit can cover both simultaneously.
What is WCAG 2.2?
WCAG 2.2 (pronounced 'wuh-cag 2.2') is the World Wide Web Consortium's globally adopted standard for web accessibility, published October 2023, defining 87 testable success criteria organised under four principles: Perceivable, Operable, Understandable, Robust.
Maintainer
World Wide Web Consortium (W3C)
Jurisdiction and enforcement
Global (referenced by most national accessibility laws). Referenced by ADA, EAA, Section 508, AODA and many others.
What is EAA?
The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.
Maintainer
European Commission
Jurisdiction and enforcement
European Union (all 27 member states). Per member state, via national transpositions.
WCAG 2.2 vs EAA — the key differences
The principal difference is jurisdictional: WCAG 2.2 applies in Global (referenced by most national accessibility laws), while EAA applies in European Union (all 27 member states). WCAG 2.2 is maintained by World Wide Web Consortium (W3C); EAA is maintained by European Commission. The standards differ on scope, conformance grading, and penalty structure — but a well-designed accessibility programme can satisfy both simultaneously by adopting the strictest applicable requirement and cross-mapping findings.
Scope
WCAG 2.2 covers: Web content, Mobile web, Web applications, PDF documents (with PDF/UA), EPUB publications. EAA covers: Consumer banking services, E-commerce (B2C online sales), Air, rail, water, bus passenger transport, Audiovisual media services and devices, Electronic communications services, E-readers and ebooks, Self-service terminals (ATMs, ticket machines), Consumer computer hardware and operating systems.
Penalties
WCAG 2.2: United States: civil penalties under ADA Title III; demand letters typically settle at $3,000–$25,000; litigated cases can reach $50,000+ in attorney-fee awards. EAA: Germany: up to €100,000 administrative fine + suspension of service.
How to comply with both at once
Adopt the stricter applicable conformance level — typically WCAG 2.2 Level AA — as your engineering baseline. Audit against that baseline once, then cross-map findings to both WCAG 2.2 and EAA specific requirements. A single Accessibility Conformance Report (ACR) using VPAT 2.5 INT can document both.
When you might need just one
If you operate exclusively in Global (referenced by most national accessibility laws) and have no cross-border procurement exposure, you may only need WCAG 2.2. The same applies in reverse for EAA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.
Sources
- Web Content Accessibility Guidelines (WCAG) 2.2 — W3C
- WCAG 2 Overview — W3C WAI
- What's New in WCAG 2.2 — W3C WAI
- Test Evaluating Web Accessibility — W3C WAI
- Directive (EU) 2019/882 (European Accessibility Act) — European Union
- EN 301 549 v3.2.1 — ETSI
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Is WCAG 2.2 stricter than EAA?
Neither standard is uniformly "stricter" — they cover different regulatory domains. WCAG 2.2 is more prescriptive about web content; EAA about consumer banking services. For organisations exposed to both, a unified WCAG 2.2 AA baseline typically satisfies the technical requirements of both.
Can a single audit satisfy WCAG 2.2 and EAA?
Yes. Both standards ultimately reference WCAG-aligned criteria. A combined audit with cross-mapped findings can produce documentation acceptable to both regulators.
Which jurisdictions enforce WCAG 2.2?
Global (referenced by most national accessibility laws). Referenced by ADA, EAA, Section 508, AODA and many others.
Which jurisdictions enforce EAA?
European Union (all 27 member states). Per member state, via national transpositions.
What happens if I am not compliant with WCAG 2.2?
United States: civil penalties under ADA Title III; demand letters typically settle at $3,000–$25,000; litigated cases can reach $50,000+ in attorney-fee awards European Union: fines under EAA national transpositions vary by member state, up to €1,000,000 in some jurisdictions Canada (AODA): C$50,000–C$100,000 per day per violation in Ontario
What happens if I am not compliant with EAA?
Germany: up to €100,000 administrative fine + suspension of service France: up to €75,000 + daily penalty up to €3,000 Italy: up to €40,000 + product/service withdrawal Ireland: up to €60,000 / 18 months imprisonment Spain: up to €1,000,000 for repeat serious infringements
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