WCAG & the Legal Baseline

The guidelines are organised under four principles — Perceivable, Operable, Understandable, Robust — with testable success criteria at three levels. A is the minimum and largely covers what makes a page usable at all. AA is the level every regulation cites: contrast ratios, resize, focus visibility, consistent navigation, error identification. AAA is aspirational and not expected as a blanket target; the W3C itself says it is not achievable for all content.

WCAG 2.2 added criteria worth knowing because they are recent enough to be missed: focus appearance requirements, a 24×24 minimum target size, dragging alternatives (any drag interaction needs a non-drag path), consistent help placement, and reduced cognitive load in authentication — which effectively rules out puzzles and memory tests as the only login route.

The legal picture has two halves. In the United States, the ADA has been applied to websites through litigation for years, with thousands of suits filed annually; Section 508 binds federal agencies and their suppliers. In the EU, the European Accessibility Act applies from 28 June 2025 to a broad set of consumer products and services — e-commerce, banking, transport, e-books — with member-state enforcement and penalties. The EN 301 549 standard, which incorporates WCAG AA, is the technical reference. The UK has the Equality Act plus public-sector regulations.

For a company selling into Europe, that changes accessibility from a values question to a compliance requirement with a deadline that has already passed.

What compliance actually involves beyond code: an accessibility statement describing conformance and known gaps, a feedback route for users to report barriers, and evidence of ongoing testing rather than a single audit. A VPAT (or its European equivalent) is commonly requested in enterprise procurement, and not having one loses deals.

Two honest caveats. Conformance is not usability — a product can meet every AA criterion and still be painful to use, which is why testing with real users matters. And an overlay widget is not compliance: automated overlays have been the subject of litigation themselves and are widely opposed by disabled users' organisations.

For US and EU-facing products this is now a legal obligation with real enforcement, and it appears in enterprise procurement as a hard requirement.

Knowing the level, the recent 2.2 additions, and the EAA date is a currency check that separates people who track this from people who remember a 2018 checklist.

• WCAG organises criteria under Perceivable, Operable, Understandable, Robust at levels A, AA, AAA.
• AA is the operative target everywhere; AAA is aspirational and not expected wholesale.
• WCAG 2.2 added focus appearance, 24×24 targets, dragging alternatives, and accessible authentication.
• The ADA drives US litigation; Section 508 binds federal procurement.
• The European Accessibility Act applies from June 2025 to most consumer digital services, referencing EN 301 549.
• Compliance includes an accessibility statement, a feedback channel, ongoing testing, and often a VPAT.
• Conformance is not usability, and overlay widgets are not compliance.