WCAG 2.2 & ADA Compliance
WCAG (Web Content Accessibility Guidelines) is the technical standard for building web content people with disabilities can use. WCAG compliance means meeting its success criteria at a chosen level — usually Level AA. In the US, ADA Title III has no published web spec, so courts and the DOJ treat WCAG conformance as the practical measure of an accessible site.
The four POUR principles
WCAG organizes every requirement under four principles. Content has to be all four for it to be accessible.
| Principle | What it means | Examples of criteria |
|---|---|---|
| Perceivable | Information must be presentable in ways users can sense | Text alternatives for images, captions, color contrast, reflow |
| Operable | Interface and navigation must be usable by everyone | Full keyboard access, no focus traps, visible focus, enough time |
| Understandable | Content and operation must be predictable | Clear labels, consistent navigation, error identification and help |
| Robust | Content must work across browsers and assistive tech | Valid markup, correct name/role/value, status messages |
Under those four principles sit the testable success criteria — 86 of them in WCAG 2.2, each assigned a conformance level.
Conformance levels: A, AA, AAA
Each success criterion is rated A, AA, or AAA. The levels are cumulative: meeting AA requires meeting every A criterion too.
- Level A is the minimum. Failing it usually makes content unusable for some group entirely — for example, an image with no alt text or a control reachable only with a mouse.
- Level AA is the operative target for almost every commercial site. It is what auditors test against and what US courts and settlements cite. Contrast of 4.5:1 for normal text, focus visibility, and consistent navigation live here.
- Level AAA is the strictest. It is not expected for a whole site — some criteria cannot apply to all content — but specific AAA items (like 7:1 contrast) are worth adopting selectively.
When someone says “WCAG compliant,” they almost always mean WCAG 2.2 Level AA.
The US legal picture: ADA Title III and Section 508
Three references overlap in the US, and they all point back to WCAG.
- ADA Title III covers “places of public accommodation.” Title III has no technical spec for websites, so plaintiffs and the DOJ use WCAG as the measuring stick. In April 2024 the DOJ finalized a rule under ADA Title II setting WCAG 2.1 AA for state and local government sites — a strong signal of where the bar sits even where it is not yet codified for private business. In practice, conforming to WCAG 2.2 AA is how you answer an ADA demand letter.
- Section 508 applies to US federal agencies and their vendors. It points directly at WCAG 2.0 Level AA, so a site built to WCAG 2.2 AA already covers it.
- Demand letters and lawsuits number in the thousands per year in US federal and state courts. A settlement plus remediation on a deadline costs far more than building to the standard up front.
A practical conformance checklist
This is a starting pass, not the full 86 criteria. It catches the failures that show up most often in audits and in lawsuits.
- Keyboard: every control is reachable and operable with the keyboard alone, with no traps. Tab order follows the visual order.
- Focus visible: a clear focus indicator on every interactive element. Do not remove outlines without replacing them.
- Color contrast: at least 4.5:1 for normal text and 3:1 for large text and UI components.
- Text alternatives: meaningful images have alt text; decorative images have empty alt (
alt=""). - Forms: every input has a programmatic label; errors are identified in text, not by color alone.
- Headings and structure: one logical heading order; landmarks and lists used semantically.
- Names, roles, values: custom widgets (modals, menus, tabs, date pickers) expose correct ARIA so assistive tech can operate them.
- Reflow and zoom: content works at 320px wide and at 400% zoom without loss.
- Media: video has captions; audio has a transcript.
- Motion: no content that flashes more than three times per second; respect reduced-motion preferences.
Why automated tools are not enough
Automated checkers like axe-core and Lighthouse catch roughly a third of WCAG issues — contrast, missing labels, structural errors — fast and at scale. The rest need a person: keyboard operability, focus order, whether a label actually describes its field, and whether a screen reader announces a custom widget correctly. A page can pass every automated check and still be unusable to someone navigating with NVDA, JAWS, or VoiceOver. Real conformance comes from combining automated scans, manual keyboard testing, and screen-reader testing.
A note on overlay widgets: third-party scripts that promise instant compliance do not make a site conformant, and several have themselves been named in accessibility lawsuits. The fix is in the markup and the components, not a script bolted on at runtime.
Where to start
Run an automated scan to find the obvious failures, then test the main flows with the keyboard and a screen reader to find the rest. Map each failure to a specific success criterion so the work is prioritized and verifiable, fix the AA gaps first, and wire checks into CI so new code starts accessible. If you want a full audit against WCAG 2.2 AA and a clear path to close the gap, get in touch.
