WCAG 2.2 explained for business owners
WCAG is the standard the legal accessibility requirements rest on. Below is what the levels mean, what version 2.2 adds and what a visitor notices from it.
- 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
- The measure today
- 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 shops
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.
The guidelines are grouped under four principles. They sound abstract, but they describe four ways a visitor gets stuck.
Under those principles sit success criteria: requirements you can test. Two people can establish independently whether a criterion is met. That is what separates WCAG from an opinion about the design.
- Perceivable: the visitor can see or hear what is there. Enough contrast, captions on video, a description for an image.
- 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. The levels stack. Meeting AA means every A criterion and every AA criterion holds, page by page. In a process of several steps, such as a checkout, every page in that process counts.
Level A is the floor. Miss something there and the site is unusable for part of your visitors: an order button that only works with a mouse, a video without an alternative, an image carrying information nobody can 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. That is why AA is the measure everywhere: in the European standard, in the rules for government websites and in what regulators expect from businesses. Across A and AA, WCAG 2.2 has 55 criteria.
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 and cover the same subjects: how the focus indicator looks, focus that is not obscured, and logging in.
| 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. |
| Dragging works without 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 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. Harmonised standards are the bridge to the technical detail, 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. Its current version, V3.2.1 from 2021, carries WCAG 2.1 at level AA, and a next version adopting WCAG 2.2 is being prepared. 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 act does not apply to every website. It covers named products and services, among them online shops, consumer banking services, e-books, telecoms, parts of passenger transport and services giving access to audiovisual media. A microenterprise providing services is exempt; the directive sets that at fewer than ten employees and an annual turnover or annual balance sheet total of at most two million euro. The exemption does not extend to products. Supervision is split by sector: online shops and electronic communications services sit with the ACM, the Dutch consumer and markets authority.
What your visitor notices
Accessibility sounds technical, but most of it is visible without measuring anything. These are the points that go wrong on most sites and that a visitor runs into straight away.
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 also reads outdoors in the sun.
- Contrast: light grey text on white does not read, not even for someone looking at their phone in the sun.
- Keyboard: people who cannot use a mouse move through the site with the tab key. Every menu, 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, what is wrong and what is expected instead.
- 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 jump through the page, the way you scan it 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. It needs words as well.
- Zooming: text has to enlarge to 200 percent without anything being lost or overlapping.
- Video: spoken words in a video need captions.
How to find out where your site stands
An automated test is the quickest first step. Tools such as axe or Lighthouse run in the browser and find within a minute what a machine can establish: missing alternative text, contrast that is too low, fields without a label.
That only covers part of it. Whether an alternative text really describes the image, whether the tab order runs logically, whether an error message makes sense: no program can settle that. It takes manual testing, with the keyboard and with a screen reader.
Test along the routes your visitors actually take, rather than page by page. Can someone using only a keyboard find a product, add it to the basket, pay and then get in touch? WCAG asks for that as well: in a process of several steps, every step counts.
An accessibility button or overlay does not solve this. Such a script puts a layer over the site and leaves the underlying code as it is, so the faults stay underneath it and a test finds them again. Record instead what was tested, when, and what was fixed.
Sources
Frequently asked questions
Is WCAG 2.2 mandatory?
Not as a version. The act sets functional requirements and names no WCAG version. EN 301 549, the European standard that supplies the technical detail, carries WCAG 2.1 at level AA in its current version, and a version with WCAG 2.2 is being prepared. The ACM states that WCAG 2.2 level AA becomes the new standard during 2026. Building to 2.2 AA also meets 2.1 AA.
What is the difference between WCAG 2.1 and 2.2?
WCAG 2.2 adds nine criteria and drops one. Six of the nine sit at level A or AA and cover the size of buttons, dragging, visible focus, logging in without a memory test, details that are not asked for twice, and help in a fixed place.
Do we have to reach level AAA?
No. The W3C itself advises against requiring AAA across an entire site, because some criteria cannot be met for some content. AA is the level the standard and the regulators look at.
Does this apply to our app as well?
Yes. 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. Browsers and assistive technology now handle those themselves, which left the criterion with no practical effect. Anyone who still has to report formally against WCAG 2.1 keeps testing it.
We have an accessibility button on the site. Is that enough?
No. Such an overlay does not change the underlying code, so the faults stay underneath it. The European umbrella body for organisations of people with disabilities and the international professional association for accessibility wrote in 2023 that overlays do not make a site accessible or compliant with the law. The fixes belong in the site itself.
Can you test our site?
Yes. We test automatically and by hand, and deliver the findings in plain language. You get the overview first, then a fixed price for the repairs.