The Web Content Accessibility Guidelines 2.2, published on 5 October 2023, represents the most significant accessibility update in five years. It adds nine new success criteria while removing one for the first time in WCAG history. For mobile app teams, the timing is critical: the UK became the first jurisdiction to mandate WCAG 2.2 in October 2024, and the EU's EN 301 549 standard is expected to incorporate 2.2 in 2026.
This article breaks down what changed, why it matters, and how to position your organisation for compliance.
The Nine New Success Criteria
WCAG 2.2 adds nine criteria across three conformance levels, with a deliberate focus on cognitive disabilities and mobile/touch interactions that WCAG 2.1 inadequately addressed.
Level A (Minimum Compliance)
3.2.6 Consistent Help requires help mechanisms (chat buttons, contact links, FAQs) to appear in the same relative position across all pages. Users with cognitive disabilities rely on spatial memory—if a chat widget moves from the bottom-right corner to the footer between pages, it creates confusion.
3.3.7 Redundant Entry prohibits requiring users to re-enter information they've already provided in the same process. Multi-step checkouts must auto-populate or offer selection of previously entered addresses. This directly addresses memory and cognitive load challenges.
Level AA (Standard Compliance Target)
2.4.11 Focus Not Obscured (Minimum) ensures that when a UI component receives keyboard focus, it's not entirely hidden by sticky headers, cookie banners, or floating action buttons. Keyboard users must see what has focus.
2.5.7 Dragging Movements requires that any functionality using drag-and-drop can also be achieved with single-pointer clicks. Sortable lists need up/down buttons; sliders need text inputs; kanban boards need "move to" menus. The W3C notes that dragging requires four discrete actions (down, hold, move, release) that many users with motor impairments cannot perform reliably.
2.5.8 Target Size (Minimum) sets 24×24 CSS pixels as the minimum touch target size, with exceptions for adequately spaced smaller targets, inline text links, and user-agent-controlled elements. This is a significant reduction from the 44×44px AAA requirement in WCAG 2.1—a pragmatic compromise that allows dense interfaces while still protecting users with motor impairments.
3.3.8 Accessible Authentication (Minimum) bans cognitive function tests as the only authentication method. Sites must support password managers (no paste blocking), offer magic links, or provide biometric alternatives. Object recognition CAPTCHAs are permitted at AA level but discouraged.
Level AAA (Enhanced Accessibility)
2.4.12 Focus Not Obscured (Enhanced) strengthens 2.4.11 by requiring that no part of the focused element be obscured—not just that it not be entirely hidden.
2.4.13 Focus Appearance specifies minimum visual requirements for focus indicators: at least 2 CSS pixels with 3:1 contrast between focused and unfocused states.
3.3.9 Accessible Authentication (Enhanced) removes the object recognition exception—even image-based CAPTCHAs fail at AAA level.
Why 4.1.1 Parsing Was Removed
For the first time, WCAG removed a success criterion. 4.1.1 Parsing, which required valid HTML markup, became obsolete because modern browsers and assistive technologies use the browser's accessibility tree rather than parsing markup directly.
Accessibility issues that would have failed 4.1.1 will fail other criteria such as 1.3.1 Info and Relationships or 4.1.2 Name, Role, Value.
For organisations still required to meet WCAG 2.0 or 2.1, the W3C retroactively considers 4.1.1 "always satisfied" for HTML and XML content. This reduces false positives in automated testing without lowering the accessibility bar.
The Legal Landscape: Who Requires What?
Understanding the relationship between WCAG versions and legal requirements is essential for compliance planning.
WCAG 2.2 vs EN 301 549
The European Accessibility Act (EAA) enforcement began 28 June 2025. However, the harmonised standard EN 301 549 v3.2.1 currently references WCAG 2.1 Level AA—not 2.2.
The updated EN 301 549 v4.1.1 incorporating WCAG 2.2 is expected in 2026. Once published in the Official Journal, it becomes the binding technical standard for both the Web Accessibility Directive (public sector) and EAA (private sector).
Strategic implication: Building to WCAG 2.2 now ensures you won't need to re-audit when EN 301 549 updates.
United Kingdom: First to Mandate WCAG 2.2
The UK's Public Sector Bodies Accessibility Regulations were amended in December 2022 to reference "the latest published version" rather than a specific version number. When WCAG 2.2 was published, UK public sector bodies automatically became subject to it. The Government Digital Service began monitoring compliance against WCAG 2.2 Level AA in October 2024.
United States: WCAG 2.1 Mandated, 2.2 Emerging in Settlements
The DOJ's April 2024 final rule mandates WCAG 2.1 Level AA for state and local government websites and mobile apps under ADA Title II. Compliance deadlines are:
- April 2026 for entities with populations of 50,000+
- April 2027 for smaller entities
Section 508, governing federal ICT procurement, remains at WCAG 2.0 since its 2017 update.
For private sector (ADA Title III), courts reference WCAG 2.1 as the de facto standard. (See our EAA vs ADA comparison for a detailed breakdown.) However, recent settlements—including Charles Schwab in late 2024—have required conformance to WCAG 2.2. With over 4,000 digital accessibility lawsuits filed in 2024, the settlement standard is shifting toward 2.2.
Mobile App Implications
Mobile accessibility presents unique challenges that WCAG 2.2 directly addresses. The W3C published "Guidance on Applying WCAG 2.2 to Mobile Applications" (WCAG2Mobile) in May 2025, providing authoritative interpretation for native iOS and Android development.
Dragging Movements on Mobile
SC 2.5.7 has profound mobile implications. Common patterns that require alternatives include:
- Swipe-to-delete: Must provide an "Edit" mode with delete buttons, or a long-press context menu
- Drag-and-drop reordering: Must offer up/down buttons or "move to" menus
- Sliders: Must include text input fields for direct value entry
- Map panning: Should include directional controls
The W3C explicitly notes that keyboard-only alternatives are insufficient for mobile—alternatives must be available via touch.
Target Size: Platform Guidelines Already Comply
The 24×24 CSS pixel minimum translates to platform-specific units:
24×24px button — too small for reliable touch input
44×44px button — meets minimum touch target requirement
Platform comparison:
- WCAG 2.2 Level AA: 24×24 CSS px
- WCAG 2.2 Level AAA: 44×44 CSS px
- Apple Human Interface Guidelines: 44×44 points
- Material Design Guidelines: 48×48 dp
Organisations following Apple or Google's platform guidelines already satisfy—and exceed—WCAG 2.2 AA requirements.
Focus Criteria: Platform Exceptions Apply
The focus-related criteria (2.4.11, 2.4.12, 2.4.13) apply to external keyboard navigation and switch control. However, focus indicator appearance on native mobile apps is controlled by the operating system. Developers receive an automatic exception for 2.4.13 since they cannot modify VoiceOver or TalkBack focus rectangles.
The focus obscuring criteria (2.4.11 and 2.4.12) remain relevant: sticky headers, floating action buttons, and bottom sheets must not cover focused elements when users navigate with external keyboards or switch controls.
The Automation Gap
Many WCAG 2.2 criteria are qualitative and resist automated testing:
- Consistent Help: Tools can find a chat button but cannot determine if its position is consistent across templates
- Accessible Authentication: Tools cannot easily identify if a field requires cognitive function
- Dragging Movements: Tools cannot know if a custom widget relies on drag events without simulation
Organisations relying solely on automated scans are likely overestimating their compliance posture. Manual testing with assistive technologies remains essential—and helps catch common accessibility mistakes that tools miss.
Preparing for WCAG 3.0
WCAG 3.0 (codenamed "Silver") is in Working Draft with finalisation expected no earlier than 2028–2030. The W3C has confirmed that WCAG 2.x will not be deprecated for "at least several years" after 3.0 is finalised.
Key changes in 3.0:
- Bronze/Silver/Gold conformance levels replace A/AA/AAA
- Graduated scoring (0–4 scale) replaces binary pass/fail
- Expanded scope covers native mobile apps, wearables, VR/AR, and voice interfaces
The W3C states: "Content that conforms to WCAG 2.2 Level A and Level AA is expected to meet most of the minimum conformance level of this new standard."
Investing in WCAG 2.2 compliance now builds the foundation for Bronze-level WCAG 3.0 conformance when it eventually arrives.
Key Takeaways
For mobile accessibility compliance, the practical impact of WCAG 2.2 concentrates in three areas:
- Provide single-tap alternatives to every drag interaction (2.5.7)
- Ensure touch targets meet the 24-pixel minimum or spacing requirements (2.5.8)
- Prevent sticky UI elements from obscuring keyboard-focused content (2.4.11)
The legal trajectory is clear: the UK already mandates WCAG 2.2, settlements are setting 2.2 as precedent, and EN 301 549 will incorporate it in 2026. Organisations that upgrade now avoid re-auditing later and reduce litigation risk today.
WCAG 2.2 is the standard for this decade. The regulatory lag means even when 3.0 arrives, it will take years for laws to reference it.
For help generating an accessibility statement that reflects your current compliance level, try —free to use, aligned with WCAG 2.1 and 2.2 requirements.