In short and in plain language
This post is about the WCAG. These are rules for accessible websites. There is a new draft for the next version.
The draft is not yet a finished standard. A lot of work is still needed. The new version will not replace the current rules.
In Germany, the BFSG is what counts. This is a law. It points to a European standard, not to the draft.
So build to the rules that apply today. Test with assistive technology and keep records. We are happy to check what your site passes on to it.
On 10 September 2026 (W3C Accessibility Guidelines 3.0, Working Draft 10/09/2026), the W3C published a new Working Draft of the W3C Accessibility Guidelines 3.0, about six months after the draft of 3 March 2026. This raises an obvious question: do ongoing BFSG projects now need replanning? The evidence-based answer is no. WCAG 3 is a working draft, not a standard. The W3C states in the document itself that several years of work (W3C Accessibility Guidelines 3.0) remain before completion, and the Web Accessibility Initiative makes clear that WCAG 3 will not supersede WCAG 2 (W3C Web Accessibility Initiative). For the legal situation in Germany, the draft changes nothing: the BFSG names no WCAG level but refers to harmonized standards; the relevant one is the European standard EN 301 549 (ETSI EN 301 549), not a W3C draft. This article places the status in context without hype, names what has changed since March and derives what product and engineering teams should actually do today.
Key takeaways
- On 10 September 2026 (W3C Accessibility Guidelines 3.0) the W3C published a new Working Draft of WCAG 3.0, the second this year after the one of 3 March 2026. A Working Draft is the earliest stage of the W3C process; Candidate Recommendation and Proposed Recommendation are still ahead.
- Every normative section carries one of five maturity levels (W3C WCAG 3.0 Explainer) from Placeholder to Mature. The guidelines and all requirements sit at Developing; the conformance chapter has moved from Exploratory to Developing since March, and no section has reached Refining.
- Instead of success criteria at A, AA and AAA, the draft uses 12 topic areas with 46 guidelines (W3C Accessibility Guidelines 3.0). In the draft, conformance means meeting all core requirements; Bronze, Silver and Gold are only reporting tiers above conformance, and that part is still being explored.
- WCAG 3 does not retire WCAG 2: after WCAG 3 is finalized, WCAG 2 will not be deprecated for several years (W3C Web Accessibility Initiative), and content meeting Level A and AA should already satisfy most of the coming baseline (W3C Accessibility Guidelines 3.0).
- For Germany what counts is the BFSG, which names no WCAG level but refers to harmonised standards: the relevant one is EN 301 549, not a W3C draft. The date worth tracking is the citation in the Official Journal of the EU of version V4.1.1 (ETSI EN 301 549), published in September 2026, which lifts the web requirements to WCAG 2.2 Level AA.
- Useful work today: reach WCAG 2.2 Level AA, log tests with assistive technology as a head start on Assertions, and review the draft twice a year. A WCAG 3 certification has no basis while the conformance model is unfinished.
What Was Actually Published on 10 September 2026
A Working Draft is the earliest public stage in the W3C standardization process. It exists to collect feedback, not to be implemented. The document says so with unusual clarity: it is inappropriate to cite the draft as anything other than work in progress (W3C Accessibility Guidelines 3.0). By comparison, the WCAG 2.2 in force today completed the entire process and were adopted as a W3C Recommendation on 5 October 2023 (W3C Web Accessibility Initiative). Between Working Draft and Recommendation, the W3C process still holds the stages Candidate Recommendation and Proposed Recommendation. WCAG 3 has reached none of them.
That said, the draft is not nothing. It organizes its requirements into 12 topic areas (W3C Accessibility Guidelines 3.0) with titles such as Images and media, Text and wording, Interactive components and Error handling, containing 46 guidelines in total, two more than in March. It includes the guidelines, requirements and assertions that have reached Developing maturity; anything still at Exploratory appears only in the Editor's Draft (W3C Web Accessibility Initiative). This progress is easily misread as "WCAG 3 is arriving now". Progress within a draft is something different from binding force. The main differences from the draft of 3 March 2026 at a glance:
| Item | Draft of 3 March 2026 | Draft of 10 September 2026 |
|---|---|---|
| Guidelines | 44 in 12 topic areas | 46 in 12 topic areas; transcripts, sign language and accessible media player now separate guidelines, media alternatives dropped |
| Maturity of conformance chapter | Exploratory | Developing |
| Conformance | levels Bronze, Silver, Gold; Bronze as minimum level | one level: all core requirements met |
| Bronze, Silver, Gold | conformance levels | reporting tiers above conformance, section at Exploratory maturity |
| Supplemental requirements | a share already needed for Bronze | not required for conformance, count from the Bronze reporting tier |
| Additional guidance | best practices | recommended practices |
Working Draft means: deliberately unfinished
While this draft has moved closer toward completion, it still has several years of work.
Reading the Five Maturity Levels Correctly
WCAG 3 introduces a feature the WCAG 2 never had: every section carries a visible maturity level. The Explainer defines five stages (W3C WCAG 3.0 Explainer) from Placeholder to Mature. This makes transparent how dependable an individual section is. That is not a detail for standards enthusiasts but the single most useful tool for judging the draft without hype: the maturity level answers whether a section can serve as a planning basis at all.
| Maturity level | What the W3C means by it | Implication for your project |
|---|---|---|
| Placeholder | The content is temporary and will be replaced entirely | Do not read as a requirement |
| Exploratory | Not refined, the direction is still being explored | No planning basis |
| Developing | Roughly agreed, high-level concerns still open | Observe, do not implement |
| Refining | Consensus reached, ready for wide review | Piloting conceivable |
| Mature | Believed by the working group to be ready for recommendation | Dependable for planning |
A look at the draft of 10 September 2026 is sobering for anyone expecting urgency: the guidelines and all requirements and assertions sit at Developing (W3C Accessibility Guidelines 3.0) maturity, the third of five stages; no section has reached Refining or Mature. According to the Explainer, Developing means that what a section needs to achieve has been roughly agreed, but that not all high-level concerns have been settled (W3C WCAG 3.0 Explainer). The conformance chapter, the very part that defines when something counts as conformant, has moved since March: it has advanced from Exploratory to Developing (W3C Accessibility Guidelines 3.0). According to the draft, much remains open nonetheless, such as the not yet defined default set of browsers and assistive technologies against which methods are tested, the limited conformance scopes still to be defined, and whether assertions can be required for conformance. The section on reporting tiers sits at Exploratory.
The decisive point
Requirements, Assertions and Methods: the New Structure
The most striking change compared with WCAG 2 is structural. The familiar system of success criteria at levels A, AA and AAA gives way to a layered architecture. The terms are still shifting from draft to draft: what the September 2025 draft called foundational requirements have been called core requirements since March 2026, and the draft of 10 September 2026 renames the former best practices to recommended practices, which are informative and not needed for conformance (W3C Accessibility Guidelines 3.0). Four building blocks carry the draft.
Guidelines (normative)
User-centred outcome statements in plain language. They describe what people must be able to achieve and are grouped by topic area rather than by the four POUR principles. The draft of 10 September 2026 lists 46 of them in 12 topic areas.
Requirements (normative)
The technically testable requirements, split into core requirements, all of which must be met for conformance, and supplemental requirements, which are not required for conformance and only count in the reporting tiers above it. They take the place of the WCAG 2 success criteria.
Assertions (normative)
Documented statements about processes carried out, such as usability testing or testing with assistive technology. They capture work that independent testers cannot verify, and the current draft does not require them for conformance.
Methods (informative)
Techniques, examples and test sets for the requirements, technology-specific or technology-agnostic. They are guidance, not obligation, and roughly correspond to today's WCAG techniques.
The conformance model is where the draft has changed most since March. In the draft of 3 March 2026, Bronze, Silver and Gold were still conformance levels: Bronze, the minimum level, required all core requirements plus a share of the supplemental requirements and assertions that was still to be determined. The draft of 10 September 2026 has only one conformance level: content conforms when it meets all core requirements (W3C Accessibility Guidelines 3.0). Bronze, Silver and Gold are now reporting tiers above conformance (W3C WCAG 3.0 Explainer); only there do supplemental requirements and assertions count, each in a number still to be determined. Below conformance, two tiers, "Avoid physical harm" and "Foundational access", are meant to show progress; for this, core requirements are tagged as physical harm, risk, barrier or friction. In the draft, this reporting part sits at Exploratory maturity (W3C Accessibility Guidelines 3.0), and the working group puts a scoring model up for discussion as an alternative (W3C WCAG 3.0 Explainer). Anyone looking to plan dependably still finds no solid basis here.
The one idea worth adopting today
Why WCAG 3 Does Not Replace WCAG 2
This is the most persistent misconception. The name suggests a replacement. The W3C explicitly contradicts that reading, and even WCAG 2.1 and 2.2 did not supersede their predecessors (W3C Web Accessibility Initiative). The draft itself states that WCAG 3 is a successor to WCAG 2.2 but does not deprecate WCAG 2 (W3C Accessibility Guidelines 3.0). The Web Accessibility Initiative is even more concrete: WCAG 3 will not supersede WCAG 2, and WCAG 2 will not be deprecated for several years after WCAG 3 is finalized (W3C Web Accessibility Initiative).
- No replacement: WCAG 3 is a successor to WCAG 2.2 but does not deprecate WCAG 2 (W3C Accessibility Guidelines 3.0).
- No deprecation after completion: WCAG 2 will not be deprecated for several years after WCAG 3 is finalized (W3C Web Accessibility Initiative).
- Coverage commitment: WCAG 3 is not to be published until it covers at least as much as WCAG 2.2 (W3C WCAG 3.0 Explainer).
- Substantial head start: content meeting WCAG 2.2 Level A and AA is expected to meet most of the future minimum level (W3C Accessibility Guidelines 3.0).
- Similar needs: the core requirements are intended to cover a similar, though not identical, set of needs as WCAG 2.2 Level AA (W3C WCAG 3.0 Explainer).
The fourth point deserves emphasis because it dismantles the entire urgency narrative. The W3C writes that content conforming to WCAG 2.2 Level A and Level AA is expected to meet most of the minimum conformance level of the new standard, and that because WCAG 3 includes additional tests and different scoring mechanics, additional work will be needed (W3C Accessibility Guidelines 3.0). The Web Accessibility Initiative puts it this way itself: the best way to prepare for WCAG 3 in the future is to meet WCAG 2.2 success criteria now (W3C Web Accessibility Initiative). Clean WCAG 2.2 AA work is therefore not a detour but the direct route. On top of that, WCAG 2.2 is now also published as ISO/IEC 40500:2025 (W3C Web Accessibility Initiative), anchoring it internationally more firmly than before. Which nine success criteria 2.2 adds over 2.1 is covered in our article on the new WCAG 2.2 success criteria.
WCAG 3 will not supersede WCAG 2 and WCAG 2 will not be deprecated for several years after WCAG 3 is finalized.
Authoritative for Germany: EN 301 549
Even if WCAG 3 were finished tomorrow, that would initially change nothing about the German legal situation. The BFSG does not reference W3C documents and names no WCAG level. In Section 4 it ties the presumption of conformity to harmonized standards whose references are published in the Official Journal of the EU; for digital offerings the relevant standard is EN 301 549 (ETSI EN 301 549). This standard carries a presumption of conformity as soon as it is cited in the Official Journal of the EU for Directive (EU) 2019/882. A W3C draft simply has no place in this chain. How the layers interlock is shown in detail in our article on EN 301 549 as the standard behind the BFSG.
| Layer | Document | Status in 2026 | Binding for you? |
|---|---|---|---|
| EU law | Directive (EU) 2019/882 (EAA) | in force | indirectly, via national law |
| National law | BFSG | applicable since 28 June 2025; names no WCAG level | included |
| Harmonized standard | EN 301 549 | V3.2.1 (WCAG 2.1) cited under Directive (EU) 2016/2102; V4.1.1 (WCAG 2.2) published by ETSI in September 2026, citation under Directive (EU) 2019/882 pending | voluntary; presumption of conformity for the BFSG once cited in the Official Journal |
| Technical benchmark | WCAG 2.1 AA (V3.2.1), WCAG 2.2 AA (V4.1.1) | W3C Recommendation | indirectly, via the standard |
| W3C draft | WCAG 3.0 Working Draft | Working Draft of 10 Sep 2026, mostly Developing maturity | not included |
What matters most for the legal situation in the foreseeable future is the evolution of the standard itself: version V4.1.1 (ETSI EN 301 549) was published by ETSI in September 2026 and raises the web requirements to WCAG 2.2 Level AA. It only confers a presumption of conformity under the BFSG once it is cited in the Official Journal of the EU under Directive (EU) 2019/882; at the time of its publication that had not yet happened (AccessibleEU). That citation is the date decision-makers should watch, not the roadmap of a W3C draft. Confusing the two leads to investment in the wrong place. Outside the web, too, the standard remains the benchmark, for instance for self-service terminals and vending machines, whose obligations stem from a dedicated chapter of EN 301 549.
How to spot WCAG 3 urgency used as a sales argument
What Teams Should Sensibly Do Today
The finding implies no standstill but a clear list of priorities. The work that has an effect today is the same as before the two drafts of 2026 – except that it is now additionally clear that it also pays into a future standard.
- Reach WCAG 2.2 Level AA properly. This benchmark covers the requirements of WCAG 2.1 AA, underlies EN 301 549 version V4.1.1 and, according to the W3C, at the same time covers most of the future minimum level (W3C Accessibility Guidelines 3.0). A WCAG 2.2 audit provides the baseline assessment: automated measurement, assessment per criterion in desktop and smartphone views including opened states, checks of keyboard operation and of the output for screen readers, and a prioritised list of findings.
- Anticipate assertions thinking. Build process documentation: who tested when with which assistive technology, which disabled people were involved, which decisions were made and why. This strengthens the accessibility statement already today.
- No switch to unfinished requirements. As long as the conformance chapter has not reached at least Refining maturity (as of 10 September 2026: Developing, W3C Accessibility Guidelines 3.0), any alignment with it is premature and creates rework.
- Keep the architecture connectable. Semantic HTML, clean focus management and testable components are valuable under any conceivable version of WCAG 3 because they are technology-independent.
- Track the standards roadmap, not the draft roadmap. What matters is when EN 301 549 V4.1.1, published by ETSI in September 2026, is cited in the Official Journal under Directive (EU) 2019/882 (ETSI EN 301 549), not when a W3C draft is updated.
- Catch regressions early. Accessibility decays with every release; ongoing BFSG monitoring keeps the achieved level stable.
This list is deliberately unspectacular. That is the point: the WCAG 3 draft does not change the task list of a BFSG project. It confirms it. Frequently recurring patterns are missing text alternatives, insufficient contrast, components that cannot be operated by keyboard and forms without associated labels. Not one of these patterns is eased by WCAG 3; all of them are solvable under WCAG 2.2 AA today.
The one real change in working mode
Build for Continuity Instead of Replanning
The evidence-based answer to the opening question is therefore: ongoing BFSG projects do not need replanning because of the drafts of 3 March and 10 September 2026. They should be continued, because the legally relevant reference point remains EN 301 549: version V3.2.1, based on WCAG 2.1 Level AA, until version V4.1.1, based on WCAG 2.2 Level AA, is cited in the Official Journal (ETSI EN 301 549, AccessibleEU). The draft is an important technical document and deserves attention from people who contribute to standards. It is not a reason to tear open a roadmap.
Our position on this is unexcited: we build against the standard that is legally authoritative today and keep projects connectable to coming standards through clean architecture. Concretely, that means accessible web development with semantic markup and testable components, a documented claim against WCAG 2.2 AA, and an accessibility statement that reflects the actual state rather than an aspiration. Teams that consider accessibility from the outset, as described in our article on accessibility by design, benefit twice at every change of standard, because the substance holds and only the testing mechanics change.
The same applies to the adjacent building blocks of a digital offering. Accessible PDF documents follow a dedicated chapter of the standard, accessible authentication is one of the nine 2.2 criteria, and where effort and benefit diverge, it is worth looking at the disproportionate burden under Section 17 BFSG. Training also pays into this continuity: a team that understands why a criterion exists will implement it correctly even when the numbering changes. And anyone who has once derived the BFSG requirements for their offering cleanly does not have to start that derivation again at a change of standard, only extend it.
Practical tip for your next roadmap round
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