Website Accessibility in 2026: WCAG 2.2, the ADA and the EAA

Website accessibility means people with disabilities can use your site: someone on a screen reader or a keyboard can find what they came for and finish the purchase or the form without help. The benchmark in 2026 is WCAG 2.2 at Level AA. Meet it and you have covered the technical core of every law in this guide.

Which law applies depends on where your customers are. If you sell to consumers in the EU, the European Accessibility Act has applied since 28 June 2025, unless you qualify as a service microenterprise. If you serve the public in the US, the ADA covers your website even though no regulation sets a technical standard for private businesses, and one tracker counted more than 5,000 lawsuits in 2025. This guide is general information, not legal advice, so talk to a lawyer in your market before a decision with real money on it.

WCAG 2.2 in plain terms

The Web Content Accessibility Guidelines (WCAG) come from the W3C, the body that sets web standards. The current version, WCAG 2.2, was first published in October 2023 and updated in December 2024, and it is also an approved ISO standard, ISO/IEC 40500:2025. Each guideline breaks down into testable success criteria at three levels.

• Level A. The floor. Failures here lock people out completely, like an image with no text alternative or a menu that only opens with a mouse.
• Level AA. The level laws and contracts point to. It adds rules such as minimum color contrast and a visible keyboard focus indicator. AA conformance means meeting every A and AA criterion.
• Level AAA. The strictest set. The W3C advises against requiring AAA as a general policy for whole sites, because some content cannot meet all of it.

So the practical target is WCAG 2.2 AA. The versions are backward compatible: content that meets 2.2 also meets 2.1, which matters because some rules still cite 2.1.

What changed in WCAG 2.2

WCAG 2.2 added nine success criteria and dropped one, 4.1.1 Parsing, which is now obsolete. Six of the new criteria sit at Level A or AA:

• 2.4.11 Focus Not Obscured (Minimum), AA. Your own content can't completely hide the element that has keyboard focus. Sticky headers and cookie banners are the usual offenders.
• 2.5.7 Dragging Movements, AA. Anything done by dragging, such as a slider, also needs a single tap or click alternative.
• 2.5.8 Target Size (Minimum), AA. Click and tap targets must be at least 24 by 24 CSS pixels or spaced apart, with exceptions such as links inside a sentence.
• 3.3.8 Accessible Authentication (Minimum), AA. Logging in can't depend on a memory test or a puzzle unless another method or some help is offered.
• 3.2.6 Consistent Help and 3.3.7 Redundant Entry, A. Keep repeated help options in the same place on every page, and don't make people retype details they already gave in the same process.

A WCAG 3 is in the works, but the W3C calls it an incomplete draft that will change and says the best preparation is meeting WCAG 2.2 now. Waiting for it gains you nothing.

The European Accessibility Act, explained

The European Accessibility Act is Directive (EU) 2019/882. EU countries had to write it into national law by 28 June 2022 and start applying those laws from 28 June 2025, so it is in force now through each country's own legislation.

What it covers

The Act lists consumer products, such as computers, smartphones and ATMs, and consumer services. For website owners the services list is what matters: e-commerce, consumer banking, passenger transport, electronic communications, e-books, and services that give access to audiovisual media.

The Directive defines e-commerce services as services provided at a distance through websites and mobile apps, at a consumer's request, with a view to concluding a consumer contract. If consumers can buy from you online, assume you are in scope. Being based outside the EU doesn't change that. A service provider is anyone who provides a service on the EU market or offers it to consumers in the EU, so on that wording a US or UK store selling to EU consumers is covered for those sales.

Some content is excluded: pre-recorded video and office files published before 28 June 2025, archives that are no longer updated, and third-party content you neither fund, develop nor control. Service contracts agreed before 28 June 2025 can run unchanged until they expire, for five years at most.

The microenterprise exemption

Microenterprises that provide services are exempt from the Act's service accessibility requirements. A microenterprise employs fewer than 10 people and has an annual turnover or an annual balance sheet total of no more than EUR 2 million. You need to pass the headcount test and at least one of the two money tests. Hire your tenth employee and the exemption ends, so plan ahead if you are growing.

Standards, enforcement and what you must publish

The Act states requirements in general terms and leaves the technical detail to harmonized standards. A service that meets a standard whose reference is published in the EU's Official Journal is presumed to conform. For digital services that standard is EN 301 549.

Its newest version, EN 301 549 V4.1.1, was published on 2 September 2026 and brings its web requirements up to WCAG 2.2 Levels A and AA. When we wrote this, its reference had not yet appeared in the Official Journal, the step that creates the legal presumption. Build to WCAG 2.2 AA and you are covered whichever way that lands.

Enforcement is national. Each EU country names authorities to check services and follow up complaints, and each sets its own penalties, which must be effective, proportionate and dissuasive. Service providers also have to explain how their service meets the requirements in their general terms and conditions or an equivalent document, and keep that public for as long as the service runs.

The ADA: what US businesses actually face

Title III of the Americans with Disabilities Act covers businesses open to the public, from shops and restaurants to clinics and hotels. The Department of Justice's guidance on web accessibility, published in March 2022 and still live on ADA.gov, says the ADA applies to what businesses offer online. It also says the DOJ "does not have a regulation setting out detailed standards" for it.

Businesses get flexibility in how they comply, and the guidance names WCAG and the federal Section 508 Standards as helpful references. So WCAG is the practical yardstick, because it is the one the DOJ itself points to.

The lawsuit numbers

The missing standard hasn't slowed litigation. UsableNet, an accessibility vendor that tracks filings, counted more than 5,000 digital accessibility lawsuits in 2025: over 3,100 in federal court and nearly 2,000 more in New York and California state courts. E-commerce drew nearly 70 percent of them. And 64 percent of the companies sued had annual revenue under $25 million, so being small is no protection.

Title II: the rule for state and local government

Title II covers state and local governments, and here a standard is codified. A 2024 DOJ rule requires their web content and mobile apps to meet WCAG 2.1 Level AA. An interim final rule published on April 20, 2026 moved compliance to April 26, 2027 for governments with a population of 50,000 or more, and April 26, 2028 for smaller ones and special district governments. The rule also covers content a contractor provides for a government, so if you build web content for a county or a public university, that work has to meet WCAG 2.1 AA.

The delay is contested. The National Federation of the Blind sued in May 2026 to restore the original deadlines, which the interim rule had pushed back by a year, so check where that case stands.

Why an overlay widget won't make you compliant

Overlays are scripts that put an accessibility icon on your site and promise compliance from one line of code. They can let a visitor enlarge text or switch colors. But the barriers live in your markup and content. A form field with no label in your code still has no label in your code.

The US Federal Trade Commission went after that promise. It alleged that accessiBe marketed its AI tool, accessWidget, as able to make any website WCAG-compliant when the tool didn't do that for all its users' sites. The final order, approved in April 2025, required accessiBe to pay $1 million and bars it from claiming its automated products can make any website WCAG-compliant, or keep one compliant, without evidence.

Widgets haven't put plaintiffs off either. UsableNet's 2025 tracking found 95 to 155 lawsuits a month against sites that had one installed. We would rather see that subscription money go into fixing your templates, where one repair carries to every page built from them.

The website accessibility checklist

Most failures are the same few problems on repeat. WebAIM's 2026 scan of the top million home pages found detectable WCAG failures on 95.9 percent of them, averaging 56.1 errors per page. Six issues made up 96 percent of those errors: low-contrast text (on 83.9 percent of home pages), missing alt text (53.1 percent), missing form labels (51 percent), empty links (46.3 percent), empty buttons (30.6 percent) and a missing page language (13.5 percent). The table maps those and the other usual suspects to WCAG 2.2.

Contrast problems usually start in the brand colors, long before anyone builds a page. That is why we test color pairings when we put together the elements of a brand identity.

Accessibility fixed in the templates is a one-time cost. Accessibility fixed page by page is a subscription you never cancel.

How to test your site properly

Start with a free automated checker such as WAVE, axe DevTools or Lighthouse, and treat the results as a first pass. When the UK Government Digital Service tested ten tools on a page with 143 planted barriers, the best single tool found 41 percent of them, and 29 percent were missed by every tool. Tools have improved since that 2017 test, but no scanner can tell you whether your alt text makes sense. For a small site, the manual checks below take an afternoon:

1. Pick your main templates. Home, a service or product page, a blog post, the contact form, and every step of checkout or booking.
2. Run the automated scan on each and clear the obvious errors first.
3. Put the mouse away. Tab through each page. Can you reach and use every link, menu, button and field, and can you always see where focus is?
4. Zoom to 200 percent, then 400 percent. Text should resize without losing content, and at 400 percent in a 1280-pixel-wide window the page shouldn't need sideways scrolling.
5. Turn on a screen reader. VoiceOver is built into Macs and iPhones, and NVDA is free on Windows. Listen for images, buttons and fields that announce nothing useful.
6. Break your forms on purpose. Submit them with mistakes and check that each error is explained in words.
7. Log, fix and retest. Record each issue against its WCAG criterion, fix by template, then repeat the keyboard and screen reader pass.

For anything that takes money or bookings, go further. The GDS team advises combining automated tools with manual checks, an accessibility audit and testing with real users.

Publish an accessibility statement

An accessibility statement tells visitors where your site stands and how to reach you when something doesn't work. The W3C's guide to accessibility statements says it should at minimum include a commitment to accessibility, the standard you apply (such as WCAG 2.2) and contact details. It also recommends listing known limitations and the environments you have tested in.

Write it in everyday language. The W3C's own example: say "videos do not have captions" instead of citing a failed success criterion. Link it from every page footer. If you sell to EU consumers, the EAA also wants this explained in your terms and conditions or an equivalent document, so keep the two consistent.

Fix it later or build it in: cost and process

Nobody can price accessibility work fairly without an audit, so be wary of a quote that skips one. Cost depends mostly on how the site was built.

Clean, consistent templates can often be fixed at the template level in a focused sprint. A page-builder site with dozens of one-off layouts is harder, because the markup is heavy and hard to control, as we covered in custom WordPress vs page builders. Sometimes rebuilding the worst components costs less than patching them.

On the retrofits we run, the order rarely changes. We audit first, then fix the shared pieces (palette, focus styles, menus, form components) so each repair spreads site-wide. Content comes next: alt text, captions, link wording, headings. Then we retest, update the accessibility statement and add the checks to every release, because new pages and plugins bring barriers back.

Building it in from the start costs the least. Contrast gets settled when the brand colors are chosen, and the screen reader pass happens before launch instead of after a demand letter. If you are planning a website redesign that keeps your Google rankings, fold accessibility into the same project. The lean, well-structured code that makes a site accessible also helps make it fast enough to convert.

That is how we run every build in our web development work, with accessibility in the spec from the first wireframe. If you want to know where your current site stands, tell us about it and we will give you a straight answer on what it needs.