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WCAG 2.2: AA is not optional (and not hard, either)

10 September 20242 min read

WCAG 2.2 has been official since October 2023. With the European Accessibility Act landing in June 2025, AA is a baseline, not a target. Here is what changes.

WCAG 2.2 has been an official W3C Recommendation since October 2023. It adds nine new success criteria over 2.1 and — more importantly — becomes the implicit baseline of the next European regulatory wave. The most relevant: the European Accessibility Act, applicable from June 28, 2025 to a wide range of digital products and services sold in the EU.

What changed from 2.1

New A and AA criteria cluster around two areas: visible focus and cleaner interactions. The main ones:

  • 2.4.11 Focus Not Obscured (Minimum) AA: the focused element must not be hidden by sticky content or overlays.
  • 2.5.7 Dragging Movements AA: every drag-and-drop operation must have a single-tap/click alternative.
  • 2.5.8 Target Size (Minimum) AA: interactive targets must be at least 24×24 px (with exceptions).
  • 3.2.6 Consistent Help A: same help mechanisms must appear in the same position across pages.
  • 3.3.7 Redundant Entry A: do not ask the same info twice in the same flow.
  • 3.3.8 Accessible Authentication (Minimum) AA: no mandatory cognitive tests for auth (no image-only captchas without alternatives).

The European Accessibility Act

EAA (Directive 2019/882, transposed in Italy by Legislative Decree 82/2022 as amended) applies from June 28, 2025 to e-commerce, banking apps, e-books, transport services and broadly a large slice of B2C digital services. The technical reference is EN 301 549, which itself points to WCAG 2.1/2.2 AA.

Translation: if you sell online to consumers in the EU with more than 10 employees / €2M turnover, you must be compliant by mid-2025.

Our four pre-launch checks

  1. Pure keyboard: navigate the entire site without a mouse. Every button must be reachable, visible, activatable.
  2. Lighthouse + axe-core: automated checks cover 30-40% of the criteria. Not enough, but a floor.
  3. Screen reader test: VoiceOver on macOS or NVDA on Windows. Five minutes on a page expose errors that tools miss.
  4. Target size sweep: every mobile button at 24px minimum. Seems obvious, yet half of design systems break this.

The most common mistake in our reviews

Focus rings removed for "aesthetics". One of the most damaging things you can do to a site. On our projects, if a designer wants the default focus gone, we replace it with a custom one — prettier, but always there. In 2024 there is no excuse.

Compliance is not perfection

WCAG 2.2 AA is a baseline. It does not mean the site is "accessible to everyone". It means we do not exclude entire categories of users due to dumb choices. AAA remains a real effort, often not fully reachable. But AA today is simply doing the job.