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WCAG 2.2 and the European Accessibility Act: what changes this year?

WCAG 2.2 is the successor to the standard on which the European Accessibility Act already relies. This article explains what changes substantively, for whom that is relevant and what remains undecided.

WCAG 2.2 is the successor to WCAG 2.1 and adds a number of new success criteria, primarily focused on forms, focus visibility and mobile device operation. The European Accessibility Directive technically refers to EN 301 549, and that standard currently refers to WCAG 2.1 level AA. This means that WCAG 2.2 is not yet a direct legal obligation, but it does indicate the direction in which the standard is moving.

For anyone managing an online shop, app or business website, the practical answer is this: what meets WCAG 2.1 AA today still meets the current legal requirement. Those who already take WCAG 2.2 into account are building towards a standard that is expected to eventually become the legal basis through a future version of EN 301 549. This is not an obligation, but a sensible choice for anyone already building or renovating.

What changes substantively

WCAG 2.2 extends WCAG 2.1; it does not replace the standard. The new criteria cover, among other things, making it clearer where focus is during keyboard operation, preventing important control elements from disappearing behind a fixed header or footer, and more consistently labeling repeated form fields such as a postal code or email field across multiple pages. A number of criteria from WCAG 2.1 have also been clarified in the 2.2 version without the requirement itself changing.

This addresses precisely the areas where things most often go wrong in practice: the checkout process, login forms and menus that must be operated with keyboard alone. Those who have already had these components tested do not need to start over; the additions build on what is already in place.

For whom this is relevant now

Organizations building a new online shop, doing a major redesign of the checkout process, or developing a new form for account management can include this in the specification without additional costs later. For existing sites that already demonstrably comply with WCAG 2.1 AA, there is no immediate reason to have everything re-tested. The legal requirement remains tied to the version of EN 301 549 currently in force.

The relationship with EN 301 549 and the law

EN 301 549 is the European standard that technically implements the European Accessibility Directive. The standard is reviewed periodically, and a future version 4 could take WCAG 2.2 as a starting point. As of the time of writing, this is not yet confirmed, and the date when a new version comes into force has not yet been set. Those who need certainty about this for a specific situation should consult the current text of the standard and directive, or involve a lawyer.

The calendar around the directive does have a fixed date that is separate from WCAG 2.2: 28 June 2030 is mentioned in the directive itself in connection with certain existing services. What that date specifically means for a particular service varies by situation and is detailed on the calendar page in the knowledge base with the key dates listed.

What you can do now

The most practical step is not to wait for a new standard version, but to determine where your current site stands in relation to WCAG 2.1 AA. A large portion of the new WCAG 2.2 criteria overlap with problems that also count under the current standard, such as unclear focus order or form fields without clear labels. Those who put this in order now are simultaneously working towards the next standard.

An automated scan, including ours, can flag some of these criteria but cannot assess everything; some points, such as whether a focus indicator is sufficiently visible in practice, require human review. This is also stated in every report we deliver. What a scan can do well is provide an initial indication of where the greatest risks lie, so you know where to prioritize.

Would you like to know where your site currently stands against the current standard, before thinking about what is still to come? Take the free quick scan of your key pages, or read in the frequently asked questions about the accessibility legislation how the standard, the directive and practice relate to each other.

This article is general information and not legal advice.