AccessivePath

Global (referenced by most national accessibility laws) · 2023

Web Content Accessibility Guidelines 2.2 (WCAG)/ wuh-cag /

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.

What is WCAG 2.2?

WCAG 2.2 extends WCAG 2.1 with 9 additional success criteria addressing cognitive disabilities, mobile interaction, and authentication usability. Conformance is graded at three levels — A (minimum), AA (standard target for legal compliance worldwide), and AAA (enhanced). It is the source standard cited by virtually every national accessibility law published since 2018.

Guiding principles

  • Perceivable: Information and UI must be presentable in ways users can perceive — alt text, captions, sufficient colour contrast.
  • Operable: UI components must be operable — keyboard accessible, sufficient time, no seizure triggers, navigable.
  • Understandable: Information and operation must be understandable — readable, predictable, with input assistance.
  • Robust: Content must be robust enough to be reliably interpreted by user agents and assistive technologies.

Conformance levels

  • Level A: Minimum level. 30 criteria. Below this, content is not accessible at all to some user groups.
  • Level AA: Standard target. 50 criteria total. The level legally required worldwide and the target most organisations should plan against.
  • Level AAA: Enhanced level. 87 criteria total. Cannot be achieved for all content (W3C explicitly notes this).

Who does WCAG 2.2 apply to?

  • Any organisation publishing public web content in jurisdictions referencing WCAG (US, EU, UK, Canada, Australia, Japan and 50+ others)
  • Software vendors selling to public-sector buyers (via VPAT requirements)
  • Mobile app publishers (referenced by mobile accessibility regulations)

Scope

  • Web content
  • Mobile web
  • Web applications
  • PDF documents (with PDF/UA)
  • EPUB publications

Penalties for non-compliance

  • 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

How to comply with WCAG 2.2

  1. Establish scope and baseline. Inventory every public-facing digital property. Run an automated baseline scan to detect the ~25–30% of WCAG criteria that machines can reliably check.
  2. Manual + assistive-technology audit. Engage IAAP-credentialed auditors to test the remaining ~70% of criteria — keyboard, screen reader (NVDA, JAWS, VoiceOver), zoom and cognitive criteria.
  3. Remediate at source. Fix issues in source code, not via overlay widgets. Train developers; integrate axe-core into CI; track open issues in JIRA or Linear.
  4. Publish an accessibility statement. Disclose conformance level, known limitations, contact for accessibility feedback, and remediation timelines. Required under EAA and best-practice under ADA.
  5. Monitor and re-test. Re-audit quarterly. Re-test before every major release. Keep an internal VPAT/ACR current and post it publicly.

Comparisons

  • WCAG 2.2 vs WCAG 2.1: WCAG 2.2 adds 9 success criteria (focus appearance, dragging movements, target size minimum, consistent help, redundant entry, accessible authentication, and three others) and removes 4.4.1 Parsing as obsolete. All 2.1 criteria carry forward.
  • WCAG 2.2 vs WCAG 3.0: WCAG 3.0 (still in W3C draft) introduces a new conformance model (Bronze/Silver/Gold scoring) and is not expected to replace 2.2 before late 2027. Plan to 2.2; track 3.0 as research.
  • WCAG 2.2 vs ADA: WCAG is the technical standard the ADA does not specify by name — DOJ rulemaking and most settlements reference WCAG 2.1 or 2.2 Level AA as the de-facto compliance target.
  • WCAG 2.2 vs EAA: The EAA references EN 301 549, which itself incorporates WCAG 2.1 AA (and is expected to update to 2.2). EAA compliance therefore requires WCAG conformance for in-scope products.
  • WCAG 2.2 vs Section 508: Section 508 was harmonised with WCAG 2.0 Level AA in the 2017 Refresh. Section 508 ICT covers federal procurement; WCAG covers anyone, anywhere.

Authoritative sources

A note on widgets and overlays

Can an accessibility widget make your site compliant?

No. Widgets adjust how content renders for individual visitors — text size, contrast modes, dyslexia-friendly fonts. They do not remediate the underlying source code. WCAG conformance is graded at source level, and US federal courts (Murphy v. Eyebobs, Suarez v. Camping World, Hernandez v. Caesars) have repeatedly held that the presence of an overlay does not preclude ADA liability.

Our product produces an IAAP-format audit report with source-level remediation guidance. If you want a preferences panel for end users, ship one separately — opt-in, disclosed, and never marketed as a compliance solution.

See the Overlay Fact Sheet, signed by 900+ accessibility professionals.

FAQ

WCAG 2.2 — frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

  • What is WCAG 2.2 and when was it published?

    WCAG 2.2 is the Web Content Accessibility Guidelines version 2.2, a W3C Recommendation published 5 October 2023. It adds 9 new success criteria to WCAG 2.1, addressing cognitive disabilities, mobile interactions, and authentication accessibility.

  • Is WCAG 2.2 legally required?

    WCAG itself is a technical standard, not a law. However, virtually every national accessibility law — ADA (US), EAA (EU), AODA (Ontario), DDA (Australia), Equality Act (UK) — references WCAG conformance as the enforcement test. WCAG 2.2 Level AA is the legal target most organisations should plan against.

  • What is the difference between WCAG Level A, AA, and AAA?

    Level A is the minimum (30 criteria) — without it, some users cannot use the content at all. Level AA (50 criteria total) is the standard target referenced by laws worldwide. Level AAA (87 criteria total) is enhanced; W3C explicitly notes it cannot be met for all content.

  • How much WCAG 2.2 can automated testing detect?

    Industry consensus and W3C-WAI guidance both place fully automated coverage at roughly 25–30% of WCAG 2.2 success criteria. The remaining 70% — including most cognitive, keyboard, screen reader, and meaningful-content criteria — requires manual review by trained auditors.

  • Can an accessibility widget or overlay make my site WCAG compliant?

    No. Widgets adjust how content renders for individual visitors (text size, contrast modes) but do not remediate the underlying code. WCAG conformance is graded against source-level criteria. Real compliance requires fixing the source code; widgets are at most a supplementary layer.

  • How often should we re-test for WCAG 2.2?

    Re-audit fully every 12 months. Run automated regression on every release. Run targeted manual testing on every significant feature change. Publish your last-updated conformance date on your accessibility statement.

  • What is a VPAT / Accessibility Conformance Report (ACR)?

    A VPAT (Voluntary Product Accessibility Template) is the standard form vendors complete to document their WCAG, Section 508, and/or EN 301 549 conformance. When filled in, it becomes an Accessibility Conformance Report (ACR). Public-sector procurement worldwide increasingly requires it.

  • When will WCAG 3.0 replace WCAG 2.2?

    WCAG 3.0 is currently a W3C Working Draft. It introduces a new conformance model and is years from Recommendation status. WCAG 2.2 will remain the legal baseline through at least 2028. Plan to 2.2; track 3.0.

Get an WCAG 2.2-grade audit. In hours.

IAAP-format report. AccessivePath maps findings to WCAG 2.2 and every related standard simultaneously.

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