WCAG 2.2: does your website meet accessibility standards?

What is WCAG 2.2? A short introduction

WCAG 2.2 is a version of the Web Content Accessibility Guidelines: an international set of recommendations for making web content more accessible to people with disabilities. It covers the way users perceive, understand and operate websites and applications, including through assistive technology.

Who developed WCAG, and why?

WCAG is developed by the World Wide Web Consortium (W3C), the international standards organisation responsible for many of the open technologies used on the web.

WCAG 2.2: what changed?

WCAG 2.2 extends the earlier 2.x guidelines with additional success criteria, including improvements for keyboard focus, target size, consistent help, accessible authentication and users with cognitive or motor disabilities.

• new criteria supporting people with cognitive and motor disabilities,
• additional guidance relevant to mobile and touch interaction,
• clearer requirements for focus, target size, help and accessible authentication.

Further standards work is continuing on WCAG 3.0, but WCAG 3.0 remains a separate, developing specification. Organisations should base current compliance decisions on the standards and legal requirements that apply to them now.

The four WCAG principles

Accessible content is organised around four principles:

1. Perceivable
Information and interface components must be presented in ways that users can perceive, for example through text alternatives, captions and sufficient contrast.

2. Operable
Users must be able to operate the interface, including with a keyboard and other assistive input methods.

3. Understandable
Content, navigation and interface behaviour should be clear, predictable and supported by useful instructions and error messages.

4. Robust
Content should use reliable semantics and remain compatible with current and future user agents and assistive technologies.

Why digital accessibility matters

Digital accessibility is both a matter of equal access and, for many organisations, a legal and commercial requirement. It improves the experience for people with permanent disabilities as well as users facing temporary or situational barriers.

The internet should work for everyone

International conventions and national law protect the rights of people with disabilities. For somebody who is blind, Deaf, has limited mobility or experiences cognitive barriers, an accessible digital service may be essential for completing an everyday task independently.

Accessibility is also a competitive advantage

Accessibility also supports a wider audience and often improves the underlying quality of the website.

• Better structure and technical quality: accessible implementation often encourages clear headings, labels and semantics.
  
• A wider audience: improvements benefit disabled and older users as well as people facing temporary or situational limitations.
  
• A stronger brand experience: removing barriers demonstrates care, competence and respect for customers.
  

2025 was a significant legal milestone

European and Polish accessibility requirements expanded in 2025. The exact duties depend on the organisation, service, company size and applicable legislation, so compliance should be assessed against the current legal text rather than a generic checklist.

WCAG and accessibility law in practice

Accessibility law now reaches beyond the public sector. For affected private services, it forms part of product and service compliance rather than an optional design enhancement.

The public sector has long-standing obligations

Polish public bodies have long been subject to the Act on the Digital Accessibility of Websites and Mobile Applications of Public Entities.

The public-sector rules apply to defined public entities and their digital services.

• government and local-authority offices,
  
• public schools and universities,
  
• healthcare institutions,
  
• courts and other public-administration bodies.
  

Their purpose is to ensure that online public information and services can be used by citizens with disabilities.

New private-sector requirements from 2025

The European Accessibility Act extended accessibility requirements to selected products and consumer services supplied by private businesses. The rules apply by sector and activity, not simply because a company owns a website.

From 28 June 2025, affected categories include selected consumer-facing services such as e-commerce, banking, passenger transport, electronic communications, access to audiovisual media services and e-books.

• E-commerce: online consumer sales and related services where the statutory scope applies.
  
• Banking and financial services: selected consumer banking, payment and financial services.
  
• Passenger transport: selected digital information and ticketing services.
  
• Access to audiovisual media services: digital access services connected with audiovisual content.
  
• Electronic communications: covered telephone and electronic communication services.
  
• E-books: e-books and dedicated software within the scope of the legislation.
  

The objective is equal access to important digital services across the EU single market.

When may the private-sector exemption apply?

The European framework includes exemptions and proportionality mechanisms. Whether they apply must be assessed in the context of the specific service and national implementation.

A microenterprise providing services may fall within an exemption where it employs fewer than ten people and its annual turnover or annual balance-sheet total does not exceed EUR 2 million. Confirm the current statutory test before relying on the exemption.

• fewer than ten employees, and
  
• annual turnover or annual balance-sheet total not exceeding EUR 2 million.
  

Even where a legal exemption applies, accessibility can improve usability, reach and professional credibility.

Penalties and enforcement: what does non-compliance risk?

Enforcement depends on the legislation and service concerned. In Poland, private-sector obligations introduced under the European Accessibility Act and public-sector digital-accessibility duties are supervised under different legal regimes.

Supervision and enforcement in Poland

Polish supervision may involve sector-specific authorities as well as bodies such as the Office of Competition and Consumer Protection (UOKiK). Public-sector digital accessibility is governed through its own statutory framework.

• Relevant market-surveillance and sector authorities, including UOKiK where its statutory remit applies.
• Public-sector oversight bodies acting under the Digital Accessibility Act.
  

Authorities can investigate non-compliance, require corrective action and use the enforcement powers granted by the relevant Act.

Potential financial and operational consequences

For private businesses, potential consequences may include orders to correct the service, restrictions affecting a non-compliant product or service and financial penalties defined by law.

For affected private services:

• an order to remove the identified non-compliance,
• restrictions affecting the supply of a non-compliant product or service,
• financial penalties calculated under the applicable legislation.

The response should be proportionate to the infringement and follow the current enforcement framework.

For public entities:

• formal enforcement for failure to meet the website, application or statement duties,
  
• orders and financial measures provided in the public-sector Act.
  

Reputational and legal consequences

The public-sector Act contains separate duties and enforcement rules. Beyond formal measures, inaccessible services can exclude customers, trigger complaints, require urgent remediation and damage trust; procurement requirements may also make accessibility relevant to eligibility or contract delivery.

• complaints or legal claims from affected users,
  
• procurement or contractual consequences where accessibility requirements apply,
  
• loss of trust among customers and partners.

How can you check whether a website meets WCAG 2.2?

A one-off automated score is not enough. Accessibility covers design, code, content, navigation, forms, documents and the complete user journey.

Automated tools: a useful first check

Automated tools can identify certain detectable failures quickly. They cannot judge every success criterion or determine whether the experience is understandable and usable.

WAVE

WAVE highlights potential issues directly on the page, including missing text alternatives, heading problems and contrast warnings. Every result still needs interpretation.

axe DevTools

The axe browser tools detect many common accessibility failures and provide technical information that helps developers investigate them.

Lighthouse accessibility audit

Chrome Lighthouse includes an accessibility audit suitable for an initial check during development. Its score represents only the rules that the tool can test automatically.

ANDI

ANDI is a browser-based inspection tool that helps reviewers examine accessible names, descriptions, structure and relationships exposed to assistive technologies.

Remember: automated checks cover only part of WCAG. Manual review and testing with disabled users are essential for understanding real barriers.

Manual testing and testing with users

Manual testing should cover:

• Keyboard navigation: verify that every function can be reached and operated without a mouse.
  
• Screen-reader testing: check names, roles, states, reading order and dynamic announcements.
  
• Contrast and text resizing: verify readability at required contrast and zoom levels.
  
• Content comprehension: assess whether language, structure and instructions are clear.
  

User testing with people who use assistive technologies can reveal barriers that a checklist or automated scanner will miss.

The role of an expert accessibility audit

A professional audit combines automated checks, manual technical review and structured testing against the applicable success criteria. An experienced auditor can:

• review representative templates and complete user journeys,
  
• identify failures that automated tools cannot detect,
  
• produce a prioritised report with evidence and remediation guidance,
  
• retest the implementation and document remaining limitations.
  

What adapting a website involves

Adapting a website is not merely a matter of satisfying technical checkpoints. The goal is to make the website clear, comfortable and understandable for people using different devices, input methods and assistive technologies.

The following areas deserve particular attention.

1. Colour contrast and text readability

Text and meaningful interface elements need sufficient contrast against their background. The design should also remain readable when text is enlarged or display settings change.

2. Alternative text

Informative images and icons need useful text alternatives. Decorative images should be ignored by assistive technology rather than described unnecessarily.

3. Keyboard navigation and visible focus

All interactive functions should be available without a mouse and the currently focused element must remain clearly visible.

• using the keyboard alone, and
  
• with a clear visible focus indicator that shows the current position.
  

Keyboard access is essential for many people with mobility or visual disabilities and benefits any user who cannot use a pointing device.

4. Form labels, validation and guidance

Every form control needs an associated label. Instructions and validation messages should explain errors in text rather than relying on colour alone, and focus should move in a predictable way.

5. Captions and transcripts for media

Prerecorded video may require captions, while audio content may require a transcript. Requirements depend on the media and applicable success criteria; autoplay should not remove user control.

What does an accessibility project with a software house involve?

Accessibility work starts with a scoped audit of representative templates and user journeys. The findings become a prioritised implementation plan with owners, acceptance criteria and a realistic schedule.

The team then corrects content, design and code: for example colour contrast, text alternatives, semantics, keyboard behaviour, forms and media. Retesting verifies whether the changes resolve the original failures and checks for regression.

Accessibility must be maintained. Content and software change, so editorial guidance, release checks, periodic reviews and a clear process for reported barriers are as important as the first remediation project.

Business benefits of adapting a website to WCAG 2.2

Although legal compliance is an important driver, accessibility also improves reach, usability and the overall quality of the digital service.

Better technical quality and search visibility

Accessible websites often benefit from clearer structure, meaningful labels, text alternatives and predictable navigation. These qualities support users and can also make content easier for search systems to process, although accessibility does not guarantee rankings.

Read Emperial’s guide to search visibility and SEO.

Reaching a wider audience

Accessibility benefits older users, people with permanent or temporary disabilities and anybody using a device in difficult conditions, such as bright sunlight, poor sound or limited dexterity.

Better conversion and user experience

Clear messages, predictable navigation and usable forms remove barriers for everyone. Fewer obstacles can improve completion rates for purchases, bookings and enquiries.

Summary

For many organisations, digital accessibility has been a legal requirement since 2025. It is also a practical opportunity to serve more people, improve the website and build a responsible brand.

If you are unsure which rules apply or how the website performs, begin with a properly scoped assessment.

We offer an initial consultation and accessibility review to identify likely priorities and recommend the next steps.

👉 Contact us to arrange a meeting with an expert.

Together, we can make the website more usable, maintainable and accessible.

WCAG 2.2: frequently asked questions

What is WCAG 2.2, and why did it become important in 2025?

WCAG 2.2 is the current 2.x version of the Web Content Accessibility Guidelines. It is a technical accessibility standard; whether and how it is legally required depends on the organisation and applicable legislation.

Which organisations are affected?

Public bodies and selected private-sector services are subject to different Polish and European rules. E-commerce, financial services, passenger transport, electronic communications and e-books are among the categories that may be in scope under the European Accessibility Act.

Does every company have to implement WCAG 2.2?

No. Scope and exemptions depend on the service and organisation. A qualifying microenterprise providing services may be exempt under the private-sector framework, but the statutory conditions should be confirmed before making that decision.

What are the consequences of non-compliance?

Authorities may require remediation and apply the measures provided in the relevant Act. The possible consequence depends on the sector, entity and infringement, so avoid relying on a generic penalty figure.

How can I check whether my website meets WCAG 2.2?

Use WAVE, axe or Lighthouse for an initial automated check, then add keyboard testing, screen-reader review and expert assessment. Automated tools cannot confirm full conformance.

How much does it cost to adapt a website?

Cost depends on the number of templates, complexity of components, content volume and severity of the findings. A small remediation may follow one audit; a large platform may require phased design, development, content and testing work.

Can accessibility be maintained under an ongoing agreement?

Yes. An ongoing agreement can cover release checks, monitoring, editor support and periodic audits so accessibility is maintained as the website changes.

What are the business benefits?

Accessibility can expand reach, improve usability and reduce friction in important customer journeys. It also supports stronger content structure and a more responsible brand.

Is there an official WCAG 2.2 certificate?

WCAG itself does not define a universal official certificate that guarantees legal compliance. A competent supplier can provide an audit report or statement of assessed conformance, but the scope, date, method and limitations should always be clear.