WCAG 2.2 vs the European Accessibility Act: What UK Businesses Need to Do Now

If you’ve heard the term WCAG 2.2 UK Businesses recently and felt uncertain whether it applies to your business, you’re not alone.

Web accessibility standards have been in flux, WCAG 2.1 became the recognised benchmark, WCAG 2.2 was published in October 2023, and the European Accessibility Act came into force for most UK businesses in June 2025. The result is a landscape where the obligations are real, the terminology is confusing, and a meaningful proportion of UK businesses remain non-compliant without fully realising it.

This article is a plain-English guide to what WCAG 2.2 and the EAA actually require, how they relate to each other, and what your business needs to do. No legal advice, just a clear picture of the technical obligations and a practical path to meeting them.

What Is WCAG?

WCAG stands for Web Content Accessibility Guidelines. It’s the international technical standard for making websites and digital content accessible to people with disabilities — covering visual, auditory, motor, and cognitive impairments.

WCAG is organised around four principles: content must be Perceivable (users can access it through multiple senses), Operable (users can navigate and interact with it), Understandable (content and interfaces are clear), and Robust (content works with current and future assistive technologies). These principles are known as POUR.

Under each principle sit specific success criteria, testable requirements at three levels: A (minimum), AA (standard), and AAA (enhanced). The level that matters for most UK businesses is AA.

WCAG 2.1, published in 2018, added 17 success criteria to the previous version, with a focus on mobile accessibility, low vision users, and cognitive and learning disabilities. It remains the most widely referenced standard in UK regulation and procurement.

WCAG 2.2, published in October 2023, adds nine further success criteria (and removes one). The additions focus primarily on users with cognitive or learning disabilities, and on mobile and touch interaction. WCAG 2.2 AA is now the current published standard, though most regulatory frameworks in the UK still reference WCAG 2.1 AA explicitly.

What Is the European Accessibility Act?

The European Accessibility Act (EAA) is EU legislation that harmonises accessibility requirements across member states for a defined range of products and services. It came into force across EU member states in June 2025.

The UK is no longer an EU member, but the EAA matters for UK businesses in two ways. First, UK businesses selling goods or services to customers in EU member states are subject to EAA requirements for those transactions. If you have customers in France, Germany, Ireland, or any other EU country, the EAA applies to the digital touchpoints of those transactions. Second, several UK-specific accessibility obligations — including the Public Sector Bodies Accessibility Regulations, explicitly reference WCAG 2.1 AA, and the EAA has prompted many private sector organisations to treat that level as a baseline, even where it isn’t strictly required.

In practical terms: if you’re a UK business operating purely domestically with no EU customer base, the EAA doesn’t directly apply. But the standard it references — WCAG 2.1 AA — is the same standard that UK procurement, public sector supply chains, and an increasing number of enterprise buyers expect from their suppliers.

What Does WCAG 2.1 AA Actually Require?

WCAG 2.1 AA is 50 success criteria. For most websites, the ones that actually fail audits most frequently are:

• Colour contrast: Text must have a contrast ratio of at least 4.5:1 against its background for normal text, and 3:1 for large text. Many brand colour palettes fail this without anyone realising until an audit is run.
• Keyboard navigation: Every function of the website must be operable via keyboard alone, without requiring a mouse. Interactive elements need visible focus indicators so keyboard users know where they are on the page.
• Alternative text for images: all meaningful images must have descriptive alt text. Decorative images must be marked as decorative so screen readers skip them.
• Form labels: every form input must have a programmatically associated label. Placeholder text alone doesn’t count.
• Error identification: when a form submission fails, the specific error must be identified and described in text, not just highlighted in red.
• No keyboard traps: users must be able to navigate away from any component using keyboard navigation. Modal dialogues and embedded media are common offenders.
• Captions for video: any pre-recorded video with audio must have accurate captions.
• Reflow: content must be accessible at 400% zoom without requiring horizontal scrolling (on a standard viewport width).

This isn’t the full list, but these are the criteria that cause the most real-world barriers for users with disabilities, and the ones most commonly found in accessibility audits of UK business websites.

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What’s New in WCAG 2.2?

WCAG 2.2 adds nine success criteria at the A and AA levels. The most practically significant for most UK business websites are:

• Focus Appearance (AA): Focus indicators must meet minimum size and contrast requirements. Many custom-styled focus rings fail this.
• Dragging Movements (AA):  Any functionality that uses a dragging gesture must also be achievable with a single pointer action. This affects sliders, carousels, and sortable lists.
• Target Size (AA):  Interactive elements like buttons and links must have a minimum target size of 24×24 CSS pixels. Small tap targets on mobile fail this frequently.
• Accessible Authentication (AA):  Login processes must not require users to perform cognitive function tests (like solving a puzzle or transcribing distorted text) unless an accessible alternative is provided.
• Redundant Entry: Users must not be required to re-enter information they’ve already provided in the same session.

The removed criterion from WCAG 2.2 is 4.1.1 Parsing, previously required correct HTML parsing; now considered redundant given how modern browsers handle HTML errors.

What Does This Mean for Your Business?

If your site was built before 2022: There’s a reasonable chance it falls short of WCAG 2.1 AA on at least some criteria. Colour contrast failures, missing form labels, keyboard navigation issues, and absent alt text are all common in sites built with older page builders or pre-2020 frameworks. An accessibility audit will tell you exactly where you stand.

If your site was built to WCAG 2.1 AA: You’re in a good position. The new WCAG 2.2 criteria are incremental, and most sites compliant with 2.1 AA will need modest changes rather than rebuilds to reach 2.2 AA.

If you sell to EU customers: Ensure your site meets WCAG 2.1 AA as a minimum. The EAA will be enforced with increasing seriousness across EU member states through 2026 and beyond.
If you’re in the UK public sector procurement supply chains, WCAG 2.1 AA is already an explicit requirement in most public sector procurement frameworks. Non-compliance can disqualify you from tenders.

The honest position is this: accessibility compliance is no longer a future consideration. It is a present legal and commercial obligation for a significant proportion of UK businesses, and the proportion is growing.

What Should You Do?

• Step 1: Audit your existing site. A proper accessibility audit against WCAG 2.1 AA will identify exactly which success criteria you’re failing and with what severity. Automated tools (like Axe or WAVE) catch around 30% of issues; manual testing and user testing with assistive technologies catch the rest. Our web development team in Gloucester and Cheltenham can run a full audit and produce a prioritised remediation list.
• Step 2: Prioritise remediation. Not all failures are equal. Issues that prevent users from accessing core content or completing key journeys (contact forms, checkout, sign-up) should be fixed first. Colour contrast and alt text issues are typically quick wins. Structural issues, keyboard navigation, focus management may require more significant development.
• Step 3: Publish an accessibility statement. UK public sector bodies are legally required to publish an accessibility statement. Private sector businesses selling to public sector buyers or EU customers should also publish one. It demonstrates good faith and documents known issues with timelines for resolution.
• Step 4: Build accessibility into new development. The most cost-effective path is to stop building inaccessible sites. WCAG compliance is significantly cheaper when it’s designed in from the start than when it’s retrofitted. We build to WCAG 2.1 AA as a non-negotiable standard on every project we take on.