WCAG 2.2

The Web Content Accessibility Guidelines are published by the W3C. Version 2.2 was first published on October 5, 2023, and republished with corrections on December 12, 2024. The structure has three layers: four principles (perceivable, operable, understandable and robust), guidelines under each principle, and success criteria under each guideline. The success criteria are what a buyer can check. W3C writes them as testable statements that do not depend on a particular technology.

Every success criterion has a level. In WCAG 2.2 there are 31 criteria at level A, 24 at AA and 31 at AAA, 86 in total. Conformance at a level means meeting every criterion at that level and all levels below it, so AA means all 55 criteria at A and AA. Conformance applies to full pages only and cannot be claimed if part of a page is excluded. When a page is one step in a process, such as a checkout or an application form, every page in that process has to conform.

WCAG 2.2 builds on 2.1 and is backward compatible: content that conforms to WCAG 2.2 also conforms to WCAG 2.0 and 2.1. It adds nine success criteria and removes one, 4.1.1 Parsing, now marked obsolete. The W3C names users with cognitive or learning disabilities, users with low vision and users with disabilities on mobile devices as the groups this version focuses on. In practice, a control must stay at least partly visible when it receives keyboard focus, pointer targets must be at least 24 by 24 CSS pixels unless an exception applies, anything done by dragging must also work with a single pointer, and login must not depend on a cognitive function test, such as remembering a password, unless there is an alternative or a mechanism that helps.

For level AAA, the W3C states that it is not recommended that Level AAA conformance be required as a general policy for entire sites, because some content cannot satisfy all AAA criteria. Two examples are 1.4.6 Contrast (Enhanced), which raises the text contrast ratio from 4.5:1 to 7:1, and 3.1.5 Reading Level, which asks for a simpler version of text that needs more than lower secondary reading ability. The easy-to-read entry covers that criterion in detail.

For a public body or a company covered by the European Accessibility Act, WCAG is the yardstick at acceptance. A contract that says "accessible" or "WCAG compliant" without a version and a level cannot be tested. Requirements for an app you are ordering:

• The contract names the version, the level and the scope: WCAG 2.2 at AA, for example, for the web app, the mobile apps and the documents the system generates. EN 301 549 covers non-web documents and software in separate clauses, so exports such as DOCX or PDF need their own checks.
• If you want AAA, list the AAA criteria you mean, for example 7:1 contrast or a simpler version of difficult text, instead of all 31 AAA criteria on every screen.
• Every requirement in the backlog carries the number of the success criterion it serves, and every criterion has a test the buyer can run at acceptance.
• Screen reader labels, error messages and status messages are content. Keep them in one catalog, write them in plain language and review them like any other text. WCAG 4.1.3 requires status messages to reach assistive technology without moving focus.
• Testing combines tools and people. Automatic checkers find missing labels and low contrast. Keyboard-only navigation, screen readers on each platform and zoom to 200% need a person.
• The new 2.2 criteria change design early: target sizes, sticky headers that hide the focused field, dragging alternatives, help links kept in the same order across pages, no re-entering data already given in the same process, and login without a memory test.
• If the system generates text with AI, the output is content too. Reading level, structure and labels apply to it, and the checks belong in the evaluation of the model.
• Acceptance ends with a report and a retest. In Poland, a public body also has to publish an accessibility statement for every language version of its site or app.

EN 301 549 is the European standard for the accessibility of ICT products and services. Version V3.2.1 (2021-03) is the harmonized standard under the Web Accessibility Directive, Directive (EU) 2016/2102, which covers public sector websites and apps; Commission Implementing Decision (EU) 2021/1339 cites it. Its clause 9 covers web content and states that conformance with WCAG 2.1 at level AA is equivalent to meeting clauses 9.1 to 9.4 and the conformance requirements of clause 9.6. Clause 10 covers non-web documents and clause 11 covers software, including mobile apps. Version V4.1.1 (2026-09), adopted on August 24, 2026, aligns clauses 9, 10 and 11 with WCAG 2.2 and was prepared for the European Accessibility Act. The standard itself states that it gives a presumption of conformity under that act once it is cited in the Official Journal of the EU.

The European Accessibility Act, Directive (EU) 2019/882, applies to listed products placed on the market and services provided to consumers after June 28, 2025. The services include e-commerce, consumer banking, e-books, electronic communications and elements of passenger transport. Under its Annex I, services must make their websites, related online applications and mobile services accessible by making them perceivable, operable, understandable and robust. Products and services that meet published harmonized standards are presumed to conform. Microenterprises providing services are exempt.

In Poland, public bodies follow the 2019 Act on digital accessibility of websites and mobile applications of public bodies (ustawa o dostępności cyfrowej stron internetowych i aplikacji mobilnych podmiotów publicznych). Its annex lists the WCAG 2.1 success criteria at levels A and AA, and the requirements are deemed met when a body satisfies clauses 9, 10 and 11 of the Polish standard implementing EN 301 549 V3.2.1. Article 10 requires an accessibility statement (deklaracja dostępności) for every language version of a website or app. Companies fall under the Act of April 26, 2024, which implements the European Accessibility Act in Poland and has applied since June 28, 2025, except to services provided by microenterprises.

For PSONI we are building Generator ETR, an app that turns documents into easy-to-read Polish. The project specification requires WCAG 2.2 level AAA. The W3C advice against AAA is about whole sites as a general policy; here the users are people with intellectual disabilities and the app has a narrow set of screens and content. The requirements list ties items to success criteria. An error message must say what to do, not only what is wrong, ideally with an example (3.3.3 Error Suggestion). Deleting a document needs a confirmation dialog with the default focus on Cancel (3.3.4 Error Prevention). Every icon needs a visible text label (1.1.1 requires a text alternative; the visible label follows the W3C cognitive accessibility guidance).

Testing in June 2026 found that text over the length limit only changed color and the character counter, while the submit button went gray with no explanation. We added a validation message next to the counter, and the retest passed in September 2026. The missing delete confirmation was fixed and passed its retest on September 21, 2026.

In September and October 2026 we adapted the web and mobile apps for screen readers and collected every ARIA label in one sheet, which also serves as the catalog of error and status messages. The first tests on the web found text that was not read at all or read character by character, Tab focus that skipped the page heading and document titles, and loading states that were never announced. The tester recommended verification by the client, and fixes from the web screen reader report are a separate open task.

On October 1, 2026, the scope of text settings was narrowed to three font sizes, 100%, 150% and 200%, which covers the 200% that 1.4.4 Resize Text names; layout at 200% still has to be tested. The settings also include a male or female voice and reading speed for text-to-speech. Typeface, spacing, margins and per-document settings were left out. DOCX is the only export format, so the generated file gets its own accessibility test of headings, lists, bold text and screen reader reading; in October 2026 that test is in progress.