WCAG 2.2 vs 2.1: What Changed and What the Law Requires

WCAG 2.2 has been the current W3C recommendation since October 2023, and in October 2025 it was also approved as an international standard, ISO/IEC 40500:2025. In September 2026 the European accessibility standard, EN 301 549, published a new version built on it. Yet most US rules and lawsuits still point to WCAG 2.1. This post explains what actually changed, which version you are held to, and which of the new rules are worth fixing now.

WCAG 2.2 vs 2.1 at a glance

WCAG 2.2 published

October 5, 2023 (W3C Recommendation)

New success criteria

Nine: six at Level A or AA, three at AAA

Removed

4.1.1 Parsing, now obsolete

Backward compatible

Yes, meeting 2.2 also meets 2.1 and 2.0

ISO standard

ISO/IEC 40500:2025, approved October 2025

What US rules cite

WCAG 2.1 AA (DOJ Title II, HHS Section 504)

The six new criteria at Level A and AA

These are the ones that matter for everyday websites. Each is short to state; the work is in finding where your site breaks them.

2.4.11 Focus Not Obscured (Minimum), Level AA

When a keyboard user tabs to a link or button, it must not be completely hidden behind something you added to the page. The usual culprits are sticky headers, sticky footers, cookie banners, and chat widgets. Test it by tabbing through a long page: if the focused item ever disappears under a fixed bar, add scroll padding or move the bar.

2.5.7 Dragging Movements, Level AA

Anything you can only do by dragging also needs a way to do it with a single tap or click. Think price-range sliders, drag-to-reorder lists, and image comparison handles. Adding plus and minus buttons, or a text field next to a slider, usually solves it.

2.5.8 Target Size (Minimum), Level AA

Clickable targets must be at least 24 by 24 CSS pixels, or have enough space around them that a 24-pixel circle centered on each does not touch its neighbors. Links inside a sentence are exempt. On small business sites this fails most often on tiny social icons, carousel dots, close buttons on popups, and quantity steppers in the cart.

3.2.6 Consistent Help, Level A

If your pages offer help, such as a phone number, a contact link, or a chat button, it must appear in the same relative place on each page. The rule does not force you to add help; it asks you not to move it around. Most sites pass this with a consistent header or footer.

3.3.7 Redundant Entry, Level A

In a multi-step process, do not make people type the same information twice. The classic example is checkout: offer a "billing address same as shipping" option or fill the field in automatically. Re-entry is still allowed when it is needed for security, such as confirming a new password.

3.3.8 Accessible Authentication (Minimum), Level AA

Logging in must not depend on a memory or puzzle test unless there is an alternative. In practice: let people paste into password and code fields so password managers work, do not block autofill, and do not rely on a CAPTCHA that asks users to transcribe distorted text. Picture-selection CAPTCHAs are still allowed at this level.

The rest: three AAA criteria and one removal

WCAG 2.2 also added three Level AAA criteria: Focus Not Obscured (Enhanced), Focus Appearance, and Accessible Authentication (Enhanced). AAA is not required by any US rule, so treat these as nice to have. And it removed 4.1.1 Parsing, the old rule about well-formed HTML, because modern browsers and assistive technology no longer depend on it.

Which WCAG version does the law require?

• ADA Title III, which covers private businesses: the law names no web standard, but courts, demand letters, and settlements measure websites against WCAG 2.0 or 2.1 Level AA.
• DOJ ADA Title II rule for state and local governments (2024): WCAG 2.1 Level AA.
• HHS Section 504 rule for federally funded healthcare (2024): WCAG 2.1 Level AA. See our healthcare deadline guide.
• European Accessibility Act: the cited standard is still EN 301 549 v3.2.1, based on WCAG 2.1 AA. The new v4.1.1, published in September 2026, is built on WCAG 2.2 but becomes the legal reference only once the European Commission cites it in the Official Journal.

So for a US small business, WCAG 2.1 AA is the line that matters in a dispute. WCAG 2.2 is where the standards are heading, and the EU is moving first.

What to fix first

Get to WCAG 2.1 AA before anything else, because that is what a demand letter cites. Our ADA compliance checklist covers it. Then add the WCAG 2.2 items in this order, since they hit the pages that matter most for online sales:

1. Accessible authentication: allow paste and autofill on login, sign-up, and one-time code fields.
2. Redundant entry: offer "same as shipping" at checkout and carry details forward between steps.
3. Target size: enlarge or space out icons, carousel dots, close buttons, and cart quantity controls.
4. Focus not obscured: tab through pages with sticky headers, cookie banners, and chat widgets.
5. Dragging movements: add click or tap alternatives to sliders and drag-and-drop.
6. Consistent help: keep contact and chat links in the same place on every page.

Can an automated checker test WCAG 2.2?

Only partly. Target size can be measured by a machine, but consistent help, redundant entry, and accessible authentication depend on how a flow behaves across steps, so they need a person to test them. Be wary of any tool that claims full WCAG 2.2 coverage from an automated scan.

To be clear about our own tool: Invoset scores WCAG 2.1 Level A and AA plus the WCAG 2.2 target size rule, and labels 2.2 findings separately. The other five 2.2 criteria are not scored, because no automated scan can test them properly. The free WCAG checker shows your baseline in about 30 seconds; use the list above for the rest. For a deeper look at the 2.1 criteria themselves, read WCAG 2.1 Level AA explained.