In short and in plain language
This is about new points in the WCAG. The WCAG are rules for accessible websites. The new version adds several new rules.
Bars or banners must not fully hide the focus. The focus shows where you are when you use the keyboard.
Anything you can drag must also work with a click. Buttons need a minimum size. You should not have to type the same data again.
Logging in needs a way without puzzles. If help appears on several pages, it stays in the same place.
Testing tools find only part of this. We check your site and support the changes.
The Web Content Accessibility Guidelines (WCAG) 2.2, published in October 2023, extend the existing standard with nine new success criteria. These specifically address gaps identified in practice since WCAG 2.1, particularly for people with cognitive disabilities, motor impairments and mobile device users. According to the WebAIM Million Report (2024), 95.9% (WebAIM Million Report, 2024) of the one million home pages analyzed had detected WCAG 2 failures. For companies subject to the BFSG, WCAG 2.2 AA is a suitable benchmark: it covers the requirements of WCAG 2.1 AA on which EN 301 549 version V3.2.1 is based, and it underlies version V4.1.1.
Key takeaways
- WCAG 2.2 adds nine success criteria and removes 4.1.1 Parsing as obsolete: two at Level A, four at AA, three at AAA. Testing against WCAG 2.2 AA means meeting six of them; EN 301 549 adopts these six in version V4.1.1.
- 2.4.11 Focus Not Obscured (AA) requires that sticky headers, cookie banners or chat widgets never fully hide the keyboard focus. The fixes are scroll-padding-top, coordinated z-index values and overlays that minimise after use.
- 2.5.7 Dragging Movements (AA) requires a single-pointer alternative for every drag, such as plus/minus buttons on a slider or a classic file picker. 2.5.8 Target Size (AA) sets 24 by 24 CSS pixels as the minimum target.
- 3.3.7 Redundant Entry (A) requires data already entered in the same process to be auto-populated or offered for selection, such as reusing the billing address for delivery. 3.3.8 Accessible Authentication (AA) demands an alternative to CAPTCHAs and other cognitive function tests.
- 3.2.6 Consistent Help (A) requires chat, phone number or FAQ link, where repeated across pages, to sit in the same relative position. 2.4.13 Focus Appearance (AAA) asks for a focus indicator at least the area of a 2 CSS pixel perimeter with 3:1 contrast between focused and unfocused states.
- Work component by component: buttons against Target Size, forms against Redundant Entry and authentication, navigation against Consistent Help. Automated tools cover only part of the criteria.
From WCAG 2.1 to WCAG 2.2: What Changed?
WCAG 2.2 builds on the foundation of WCAG 2.1 and adds nine new success criteria, while one existing criterion (4.1.1 Parsing) has been removed as obsolete. The new criteria are distributed across three conformance levels: two at Level A, four at Level AA and three at Level AAA. Six of the nine new criteria therefore count towards WCAG 2.2 AA conformance. EN 301 549, to which the BFSG refers via harmonised standards, adopts exactly these six in version V4.1.1; version V3.2.1 is still based on WCAG 2.1.
The content focus of the new criteria lies in three areas: focus management (Focus Not Obscured, Focus Appearance), motor accessibility (Dragging Movements, Target Size) and cognitive accessibility (Redundant Entry, Consistent Help, Accessible Authentication). These priorities reflect the recognition that previous WCAG versions primarily addressed visual and auditory barriers while cognitive and motor impairments were underrepresented.
For companies already WCAG 2.1 AA-compliant, the effort for migration to WCAG 2.2 is manageable. The new criteria affect specific interaction patterns that can be efficiently tested in a targeted WCAG audit. Those who still do not meet fundamental 2.1 requirements should address these first.
Focus Not Obscured: Visible Keyboard Focus
Criterion 2.4.11 Focus Not Obscured (Minimum) at Level AA requires that the keyboard focus is not completely hidden by other page elements. In practice, this means: when a user navigates through the page using the Tab key and an element receives focus, that element must not disappear behind a sticky header, a cookie banner, a chat widget or another overlaying element.
This criterion addresses a common problem on modern websites. Sticky headers with a height of 60 to 80 pixels regularly obscure focused elements at the top of the page. Cookie banners at the bottom of the screen overlay footer links. Chat widgets in the lower right corner cover form fields. For keyboard users who cannot visually track the focus, these elements become invisible and thus unusable.
Technical implementation requires careful coordination of z-index values, scroll-padding rules and focus management. Sticky headers need appropriate scroll-padding-top on the HTML element so that focused elements scroll below the header. Cookie banners should be minimized after interaction and not permanently block the lower area. The stricter AAA variant (2.4.12) requires the focused element to be fully visible, not just partially.
Dragging Movements: Alternatives to Drag-and-Drop
Criterion 2.5.7 Dragging Movements at Level AA requires that any function requiring drag-and-drop can also be performed via a single-pointer alternative. This means: every interaction requiring a dragging motion must also be achievable through simple tapping or clicking. This criterion is particularly relevant for users with motor impairments who cannot perform precise dragging movements.
In practice, this criterion affects numerous common UI patterns: sliders and range inputs operated by dragging, drag-and-drop sorting in lists and kanban boards, file uploads via drag-and-drop, carousels with swipe gestures and map applications with panning interaction. For each of these patterns, an alternative operating method must exist.
For sliders, a numeric input or plus/minus buttons serve as alternatives. Sortable lists can receive additional up/down buttons. File uploads need a classic file selection button alongside the drop area. Carousels need forward/backward controls. These alternatives improve not only accessibility but often also general usability, as not all users find drag interactions intuitive. Accessible web development considers these patterns from the start.
Target Size Minimum
Criterion 2.5.8 (AA): Interactive targets must be at least 24x24 CSS pixels or have sufficient spacing from neighboring targets.
Focus Appearance
Criterion 2.4.13 (AAA): The focus indicator must be at least as large as a 2 CSS pixel thick perimeter and reach a contrast of 3:1 between focused and unfocused states.
Consistent Help
Criterion 3.2.6 (A): Help mechanisms such as chat, phone or FAQ that are repeated across pages must appear at the same relative position on each of them.
Accessible Authentication
Criterion 3.3.8 (AA): Cognitive function tests like CAPTCHAs must not be the only authentication method. Alternatives must exist.
Redundant Entry
Criterion 3.3.7 (A): Information the user has already entered in the same process must be auto-populated or available to select unless re-entry is essential.
Focus Not Obscured
Criterion 2.4.11 (AA): Keyboard focus must not be completely obscured by other elements such as sticky headers or overlays.
Redundant Entry: No Duplicate Data Input
Criterion 3.3.7 Redundant Entry at Level A is one of the most practically relevant new criteria. It requires that information the user has already entered in a process does not have to be typed in again but is auto-populated or available to select, unless re-entry is essential to the function. The classic example: when a user enters their billing address in checkout, the shipping address field should be able to automatically adopt this data.
This criterion primarily targets people with cognitive disabilities for whom repeated data entry represents a significant burden. But the principle also makes sense for all other users: fewer inputs mean fewer errors, faster processes and higher conversion rates. According to Baymard Institute, 17% (Baymard Institute) of surveyed US online shoppers have abandoned an order because of a too long or complicated checkout process.
Implementation requires a well-thought-out form architecture. Multi-step forms must enable data carry-over between steps. Checkout processes need an option to adopt the billing address as the shipping address. Registration forms should carry over data from the ordering process. Autocomplete attributes per the HTML standard facilitate automatic population by the browser. All these measures are part of accessible shop development.
Target Size: Sufficiently Large Click Targets
Criterion 2.5.8 Target Size (Minimum) at Level AA defines that interactive elements must be at least 24x24 CSS pixels in size. Alternatively, an element may be smaller if the distance to neighboring interactive elements is large enough to prevent accidental activation. This criterion particularly affects mobile interfaces, where small touch targets are a common problem.
In practice, many websites violate this criterion without knowing it. Icons in navigation bars measuring only 16x16 pixels, social media links at 20x20 pixels, tightly spaced checkbox groups and small close buttons in modals regularly fall below the minimum size. The AAA variant (criterion 2.5.5 from WCAG 2.1) even recommends 44x44 CSS pixels as target size.
Implementation is technically straightforward: CSS rules ensure all interactive elements meet the minimum size. For icons that should appear visually smaller, the clickable area can be enlarged via padding without changing the visual design. Verification can be automated, for example through tools that measure the bounding box of all interactive elements and check against the threshold.
Accessible Authentication: Barrier-Free Login
Criterion 3.3.8 Accessible Authentication (Minimum) at Level AA requires that authentication processes do not require cognitive function tests unless an alternative is available. Specifically: if a login process contains a CAPTCHA requiring letter recognition, puzzles or math problems, an alternative method must be offered.
Acceptable alternatives include password manager support through correct autocomplete attributes, copy-and-paste capability for verification codes and biometric authentication such as fingerprint or facial recognition. CAPTCHAs that only require recognizing objects are expressly excepted at Level AA; this exception does not apply at Level AAA (3.3.9). The goal is that people with cognitive disabilities are not locked out by the authentication process.
For e-commerce websites, this criterion has direct implications for login, registration and checkout processes. Contact forms with CAPTCHAs need alternative spam protection mechanisms such as honeypot fields or server-side time checks. Accessible authentication can also improve conversion rates, as CAPTCHAs can be a reason for abandonment.
Consistent Help: Help Always in the Same Place
Criterion 3.2.6 Consistent Help at Level A requires that help mechanisms repeated on multiple pages of a website appear at the same relative position on each of them. If a chat icon appears on several pages, it sits in the same place on every one of them. If the phone number appears in the header on several pages, it must be in the same place there each time. The criterion does not require help to be offered on every page.
This criterion addresses the needs of people with cognitive disabilities who rely on predictable layouts. Searching for and rediscovering help elements in different positions represents a significant cognitive burden for this user group. The solution is simple: help elements are implemented as part of the global layout, not as page-specific components.
Affected help mechanisms include live chat widgets, phone numbers and email addresses in the context area, FAQ links or help buttons, contact form links and self-service portals. All these elements should be anchored in a consistent header or footer structure that does not change across the entire website. Accessible web development implements this consistency as an architectural principle.
Focus Appearance: Visible Focus Indicators
Criterion 2.4.13 Focus Appearance at Level AAA defines strict requirements for the visibility of focus indicators. The focus indicator must have a contrast of at least 3:1 between the focused and unfocused states and be at least as large as a two CSS pixel thick perimeter of the element. Although this criterion is at AAA level and thus not directly BFSG-mandated, we recommend implementation as visible focus indicators are fundamental for keyboard navigation.
Many websites use outline: none in their CSS, removing the browser's default focus indicator. This looks visually cleaner but makes the site unusable for keyboard users. The better solution: implement a custom focus indicator matching the design with sufficient contrast. The CSS property :focus-visible enables showing the focus ring only during keyboard navigation, not on mouse clicks.
A well-designed focus indicator uses a combination of outline and offset to ensure the ring is not obscured by the element itself. Color-wise, it should clearly stand out from the background. On dark backgrounds, a light focus ring is recommended; on light backgrounds, a dark one. A consistent focus strategy across the entire website strengthens predictability and improves the user experience for all keyboard users.
Implementing WCAG 2.2 in Practice
Implementation of WCAG 2.2 criteria should proceed systematically. As a first step, a comprehensive audit is recommended that checks the current state against all WCAG 2.2 AA criteria. Results are summarized in a prioritized action plan that addresses the most critical issues first.
For technical implementation, we recommend a component-based approach: each UI component is individually checked against the relevant criteria and adjusted as needed. Buttons and links are checked for Target Size. Forms are tested for Redundant Entry and Accessible Authentication. Navigation is validated for Consistent Help and Focus Not Obscured. This modular approach enables stepwise migration without interrupting ongoing operations.
Particularly important is integrating WCAG requirements into the development process. New features should be developed against WCAG 2.2 from the start. Code reviews should include accessibility as a fixed review criterion. Automated tests catch a portion of problems but do not replace manual testing by trained testers. Our training programs provide developers and designers with the necessary competencies for accessible development in daily practice.
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