WCAG 2.2 is the current international standard for web accessibility. The W3C published it in October 2023, and it applies directly to UK businesses through the Public Sector Bodies Accessibility Regulations and the Equality Act 2010. It adds nine new success criteria beyond WCAG 2.1, with a clear focus on users with cognitive disabilities and people who navigate by touch or keyboard. This article explains the key changes, highlights the criteria that matter most for UK compliance, and outlines the practical steps businesses should take to meet the standard.
Key takeaways
- WCAG 2.2, published October 2023, added nine new or updated success criteria.
- The new criteria focus on focus visibility, authentication, and drag-based interactions.
- UK businesses risk Equality Act 2010 discrimination claims if their websites are inaccessible.
- Public sector bodies must comply with the Public Sector Bodies Accessibility Regulations 2018.
- Automated tools like axe DevTools catch only 30–40% of accessibility issues.
- Focus indicators need a minimum 2px solid outline with a 3:1 contrast ratio.
- To pass SC 2.5.7, drag-based widgets require a single-pointer alternative, such as reorder buttons.
What Changed in WCAG 2.2: The Nine New and Updated Criteria
Check the WCAG 2.2 specification against your current site before commissioning any redesign work. It costs less to build accessibility in from the start than to retrofit changes later.
WCAG 2.2, published in October 2023, added nine success criteria across three areas. They cover focus visibility, authentication, and drag-based interactions.
Focus and interaction changes make up five criteria. SC 2.4.11 requires keyboard focus indicators to remain fully visible. SC 2.4.12 sets minimum size and contrast thresholds for those indicators. SC 2.5.7 requires any drag-based functionality to offer a single-pointer alternative, and SC 2.5.8 sets a minimum target size of 24×24 CSS pixels for interactive elements.
Cognitive and authentication criteria cover a wider range of users. SC 3.2.6 requires consistent help mechanisms to appear in the same location across pages. SC 3.3.7 stops users from having to re-enter information already submitted within the same session. SC 3.3.8 and SC 3.3.9 prevent distorted-text tests from being the sole authentication method unless an alternative exists.
All nine criteria apply at Level AA. That is the compliance level referenced in most UK public sector accessibility regulations and supplier contracts.
UK Legal Context: Equality Act 2010 and Public Sector Accessibility Regulations
| Area | Private sector | Public sector |
|---|---|---|
| Main legal basis | Equality Act 2010 | Equality Act 2010 plus Public Sector Bodies Accessibility Regulations 2018 |
| Who is covered | Any organisation providing goods, services, or facilities to the public | Central government, local councils, NHS trusts, and publicly funded schools |
| Minimum standard referenced | WCAG conformance used as evidence of reasonable adjustment | WCAG 2.1 AA minimum plus accessibility statement |
| Current practical direction | Align to WCAG 2.2 to reduce legal and remediation risk | Work towards WCAG 2.2 as the current standard |
UK businesses that fail to meet accessibility standards can face discrimination claims under the Equality Act 2010. The Act requires service providers to make reasonable adjustments for disabled users. An inaccessible website can breach that duty, even if the organisation did not intend to discriminate.
Public sector bodies face a stricter regime under the Public Sector Bodies Accessibility Regulations 2018. These regulations mandate compliance with WCAG 2.1 AA as a minimum and require a published accessibility statement. The Cabinet Office enforces the regulations, and non-compliant bodies risk formal notices. WCAG 2.2 is not yet the mandated standard under those regulations, but aligning to it now reduces remediation risk if the threshold is raised.
Private sector organisations are not subject to the 2018 regulations, but the Equality Act still applies. Courts and tribunals use WCAG conformance as evidence of reasonable adjustment. That makes the standard practically relevant, even where it carries no direct statutory weight.
Which Businesses and Websites Must Comply
The Equality Act 2010 applies to any organisation that provides goods, services, or facilities to the public, regardless of size. A sole trader running an e-commerce site has the same reasonable adjustment duty as a national retailer.
Public sector bodies face the strictest obligations. Under the Public Sector Bodies Accessibility Regulations 2018, central government, local councils, NHS trusts, and publicly funded schools must meet WCAG 2.1 AA as a minimum and publish an accessibility statement. WCAG 2.2 AA is now the current standard, and public bodies are expected to work towards it.
Private sector organisations are not directly bound by the Regulations, but the Equality Act still covers charities, membership organisations, and financial services firms. Any site that enables booking, purchasing, account management, or information retrieval counts as a service under the Act.
Employee-facing systems fall under the Act’s employment provisions, not its service provisions. The duty to make reasonable adjustments for disabled employees still applies. Intranet platforms and HR portals are not exempt.
How to Audit Your Site Against WCAG 2.2 Standards
Automated tools such as axe DevTools and WAVE catch roughly 30–40% of accessibility issues. They flag missing alt text, poor colour contrast, and unlabelled form fields. Manual testing covers the rest.
Test keyboard-only navigation next. Tab through every interactive element and confirm a visible focus indicator that meets SC 2.4.11 (minimum 2px outline with sufficient contrast). For drag-based functionality, verify that an equivalent keyboard or pointer action exists, as required by SC 2.5.7.
Use screen reader testing with NVDA or VoiceOver to catch interactions automated tools miss. Check authentication flows against SC 3.3.7, which prohibits cognitive function tests at login without an alternative. Test forms end to end to confirm that error messages are announced and labels stay linked to their inputs.
Document each finding against its WCAG 2.2 success criterion and conformance level. Publish an accessibility statement that lists known issues, remediation timescales, and a contact route for users who encounter barriers. Reassess after any significant redesign or content update.
Steps to Fix the Most Common WCAG 2.2 Failures
Focus indicators fail WCAG 2.2 more often than any other criterion. Add a minimum 2px solid outline with a 3:1 contrast ratio to all focusable elements. CSS :focus-visible handles this cleanly and does not affect mouse users.
Drag-based widgets, including carousels, sortable lists, and map controls, need a single-pointer alternative to satisfy SC 2.5.7. Reorder buttons or directional arrow controls meet that requirement. Check that these alternatives also work with keyboard-only navigation.
Authentication flows often fail SC 3.3.7 and 3.3.8. Allow password manager autofill, copy-paste input, or one-time codes. These remove steps that force users to recall credentials from memory.
SC 3.2.6 requires navigation components to stay in the same position across every page. Set this rule at the component library level to prevent inconsistency on larger sites. W3C’s Understanding document for SC 3.2.6 covers accepted patterns for help mechanisms.
Single-character keyboard shortcuts in single-page applications often breach SC 2.1.4. Any such shortcut must be remappable or deactivatable. Audit custom JavaScript key bindings and provide a settings panel when shortcuts conflict with assistive technology commands such as NVDA’s letter navigation.
Frequently Asked Questions
What is WCAG 2.2 and how does it differ from WCAG 2.1?
WCAG 2.2 is the current Web Content Accessibility Guidelines standard. The W3C published it in October 2023. It builds on WCAG 2.1 and adds nine new success criteria focused on keyboard navigation, authentication, and mobile usability. All existing 2.1 criteria remain, so meeting 2.2 automatically satisfies 2.1.
Does WCAG 2.2 apply to private sector businesses in the UK?
Your legal duty depends on your sector. Public sector organisations have a statutory duty under the Public Sector Bodies Accessibility Regulations 2018. Private businesses have no equivalent legal requirement, but WCAG 2.2 compliance reduces discrimination risk under the Equality Act 2010 and is increasingly expected by clients, partners, and consumers.
Which new WCAG 2.2 success criteria are most relevant for UK business websites?
Prioritise Focus Appearance (2.4.11), Dragging Movements (2.5.7), and Target Size (2.5.8). These criteria affect the widest range of users on standard business websites. If your site includes login or checkout flows, Accessible Authentication (3.3.8) is also critical.
How can a UK business check whether its website meets WCAG 2.2 requirements?
Automated tools such as Axe, WAVE, or Lighthouse catch roughly 30–40% of WCAG issues. Manual testing finds the rest, including keyboard navigation, screen reader compatibility, and cognitive usability checks that no scanner detects automatically. Used together, and paired with user testing with disabled participants, these methods give the most reliable assessment.
What legal and commercial risks can arise if a business does not meet WCAG 2.2 standards?
Around 16 million people in the UK live with a disability. Businesses that fail WCAG 2.2 standards risk claims under the Equality Act 2010, which requires reasonable adjustments to digital services. Inaccessible sites also lose customers who cannot use them. That cuts revenue and harms brand reputation.
