WCAG 2.2 explained for business owners

WCAG is the standard the legal accessibility requirements rest on.

What it is: guidelines from the W3C; a W3C Recommendation from October 2023, revised in December 2024
Which level counts: level AA; 55 success criteria across A and AA, six of them new in 2.2
Current yardstick: WCAG 2.1 AA; through EN 301 549 V3.2.1, the version tested against in practice
What is changing: WCAG 2.2 AA during 2026; announced by the ACM, the regulator for online stores

What WCAG is

WCAG stands for Web Content Accessibility Guidelines: the guidelines for accessible websites from the W3C, the standards body of the web. It is not a law in itself, but it is the standard the European and Dutch rules rest on.

Three versions are in use: 2.0 from 2008, 2.1 from 2018 and 2.2 from October 2023, last updated in December 2024. Each version builds on the one before it. The W3C states that content conforming to 2.2 also conforms to 2.1 and 2.0.

WCAG consists of success criteria: requirements you can test. Two people can establish independently whether a criterion is met.

The criteria are grouped under four principles.

Perceivable: the visitor can see or hear what is there, with enough contrast and a text alternative for images and sound.
Operable: everything works without a mouse, using the keyboard alone, and there is enough time to finish a task.
Understandable: the language can be followed, the site behaves predictably and an error in a form is explained.
Robust: the code is sound, so a screen reader or other assistive technology can work with it.

A, AA and AAA: what the levels mean

Every success criterion has a level: A, AA or AAA. Each level includes the one below it. Meeting AA means meeting every A criterion and every AA criterion, page by page. In a process of several steps, such as a checkout, every page in that process counts.

Level A is the minimum. If a site fails at that level, it is unusable for some of your visitors, for example because of an order button that only works with a mouse, or an image carrying information a screen reader cannot read out.

Level AA adds the requirements that decide, for large groups of people, whether someone can complete an order unaided: contrast between text and background, text that can be enlarged to 200 percent without anything being lost, a visible focus for people working from the keyboard, and error messages that say exactly what is wrong.

Level AAA is the highest level and is deliberately not meant as a blanket requirement. The W3C writes that not all AAA criteria can be met for all content, and advises against requiring AAA across an entire site. AA is the level used in the European standard and in the rules for government websites.

What is new in WCAG 2.2

WCAG 2.2 adds nine success criteria to version 2.1 and drops one. The criterion that went was about errors in the HTML code. Browsers and assistive technology now handle those themselves, which left the requirement with no practical effect.

Six of the nine new criteria sit at level A or AA, so they count as soon as you take AA as your target. Many of them are about using a site on a phone and about people who find it hard to remember and concentrate.

The other three sit at level AAA: two about focus and one about logging in.

The six new requirements in WCAG 2.2 at level A and AA, translated into what a visitor notices
New requirement	What your visitor notices
Size of buttons and links	A button is at least 24 by 24 CSS pixels or has enough space around it, so you do not hit the wrong one on a phone.
Alternative to dragging	Anything you can drag, such as a slider or a map, also works with a single tap or click.
Focus stays visible	Someone navigating by keyboard can see where they are. A sticky bar or a notice at the bottom must not cover that completely.
Logging in without a memory test	Remembering a password or solving a puzzle must not be the only way to log in: there has to be an alternative or an aid, such as a password manager filling the field.
Not asking the same thing twice	Details you entered earlier in the same order or application are already filled in or can be selected.
Help in a fixed place	If a phone number, contact form or chat appears on several pages, it sits in the same place in the order of the page everywhere.

WCAG, EN 301 549 and Dutch law

The European accessibility directive, Directive (EU) 2019/882, was transposed in the Netherlands as the Implementatiewet toegankelijkheidsvoorschriften producten en diensten. It has applied since 28 June 2025.

The act names neither WCAG nor EN 301 549. It sets functional requirements: what a service has to let someone with a disability do. The technical detail comes from harmonised standards, and for this directive no standard has been cited in the Official Journal of the European Union yet. The formal presumption of conformity therefore cannot be relied on.

In practice, testing is done against EN 301 549, the European standard for accessible ICT. For websites, documents and software it adopts the text of WCAG. The version tested against, V3.2.1 from 2021, carries WCAG 2.1 at level AA; V4.1.1, with WCAG 2.2, was published in September 2026 but has not yet been cited in the Official Journal. The ACM applies WCAG 2.1 level AA and states that WCAG 2.2 level AA becomes the new standard during 2026. Build to 2.2 AA now and you meet both.

The article on the accessibility act covers which businesses the act applies to and who supervises it.

What your visitor notices

You can check most of these points without measuring anything.

Nearly everything on this list helps visitors without a disability too. A form that explains what went wrong is easier for anyone to finish, and text with enough contrast is also easier to read outdoors in sunlight.

Contrast: light grey text on white is hard to read.
Keyboard: people who cannot use a mouse move through the site with the tab key. Every button and form has to work that way, and you have to be able to see where you are.
Forms: every field has a visible label, and an error is explained in words: which field it is and what needs to change.
Images: an image that carries information gets a description in text. A decorative image gets none.
Headings: headings in the right order let a screen reader user jump from heading to heading, the way you scan a page with your eyes.
Colour on its own is not enough: a red border around a field says nothing to someone who cannot see that difference, so the error also has to be explained in words.
Video: spoken words in a video need captions.

How to test whether your site complies

An automated test is the quickest first step. Tools such as axe or Lighthouse run in the browser and find what a machine can establish, such as missing alternative text or contrast that is too low.

Whether an alternative text accurately describes the image and whether the tab order runs logically is something you establish by hand, with the keyboard and with a screen reader.

Test the routes your visitors take from start to finish. Can someone using only a keyboard find a product, add it to the basket, pay and then get in touch?

Keep a record of each test and of what was fixed.

Sources

Frequently asked questions

Is WCAG 2.2 mandatory?

The act names no WCAG version; the ACM currently applies WCAG 2.1 level AA and states that WCAG 2.2 level AA becomes the new standard during 2026.

What is the difference between WCAG 2.1 and 2.2?

WCAG 2.2 adds nine criteria, six of them at level A or AA, and drops one.

Do we have to reach level AAA?

AA is the level the standard and the regulators look at.

Does this apply to our app as well?

EN 301 549 covers ICT broadly, mobile apps included, and the ACM addresses websites and apps together in its call to businesses. The requirements are the same; only the way of testing differs.

Why was that one criterion dropped?

It was about errors in the HTML code, and browsers and assistive technology now handle those themselves. An audit against EN 301 549 V3.2.1 may still include it, because that version predates the W3C note that treats the criterion as always met.

We have an accessibility button on the site. Is that enough?

Such an overlay does not change the underlying code, so the faults in the site remain.

Can you test our site?

We test automatically and by hand, and deliver the findings in a report. You get the overview first, then a proposal for the repairs.