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WCAG 2.2 vs. WCAG 2.1: What Changed and What It Means for Section 508

Maximilian Simkins, Simkins & Elgazar
WCAGSection 508Accessibility StandardsCompliance

The Web Content Accessibility Guidelines (WCAG) 2.2 became a W3C Recommendation in October 2023, adding 9 new success criteria to the 78 criteria already established in WCAG 2.1. For organizations subject to Section 508 requirements, this raises practical questions: what changed, does it apply now, and should testing practices be updated?

What WCAG 2.2 Added

WCAG 2.2 introduced 9 new success criteria, primarily focused on improving accessibility for users with cognitive disabilities and users on mobile devices. All 9 are at Level A or AA:

2.4.11 Focus Not Obscured (Minimum), Level AA When a user interface component receives keyboard focus, it must not be entirely hidden by other content. This addresses the common problem of sticky headers or footers covering the focused element.

2.4.12 Focus Not Obscured (Enhanced), Level AAA The focused component must be fully visible, not just partially visible.

2.4.13 Focus Appearance, Level AAA The focus indicator must meet minimum size and contrast requirements.

2.5.7 Dragging Movements, Level AA Any functionality that requires dragging must also be operable with a single pointer without dragging. This ensures users with motor disabilities can access drag-and-drop interfaces.

2.5.8 Target Size (Minimum), Level AA Interactive targets must be at least 24x24 CSS pixels, with some exceptions. This improves usability for users with motor impairments and on touch devices.

3.2.6 Consistent Help, Level A If a help mechanism is available on multiple pages, it must appear in the same relative location on each page.

3.3.7 Redundant Entry, Level A Information previously entered by the user in the same process must be auto-populated or available for selection, reducing the need to re-enter data.

3.3.8 Accessible Authentication (Minimum), Level AA Authentication processes must not require cognitive function tests (like puzzles or memory challenges) unless an alternative is available.

3.3.9 Accessible Authentication (Enhanced), Level AAA A stricter version that prohibits any recognition-based cognitive test in authentication.

WCAG 2.2 also removed one criterion from 2.1: Success Criterion 4.1.1 (Parsing) was deprecated because modern browsers and assistive technologies no longer require it.

What This Means for Section 508

The Revised Section 508 Standards, published in 2017, incorporate WCAG 2.0 Level AA by reference. They do not currently reference WCAG 2.1 or 2.2.

However, this does not mean WCAG 2.2 is irrelevant to federal contractors:

WCAG 2.1 is backward-compatible with 2.0. Any product that conforms to WCAG 2.1 AA also conforms to WCAG 2.0 AA. Similarly, WCAG 2.2 AA conformance includes all of WCAG 2.1 AA and WCAG 2.0 AA.

Agencies are already moving ahead. Many federal agencies have adopted WCAG 2.1 AA as their de facto standard, even though Section 508 formally references WCAG 2.0. The Access Board has indicated that updates to Section 508 referencing newer WCAG versions are expected.

ADA Title II explicitly requires WCAG 2.1 AA. The DOJ's 2024 final rule under ADA Title II specifies WCAG 2.1 Level AA as the compliance standard for state and local government websites. Organizations subject to both Section 508 and ADA Title II should test against WCAG 2.1 AA at minimum.

Best practice is to test against WCAG 2.1 AA now and prepare for 2.2. Testing against 2.1 AA satisfies all current legal requirements while positioning your organization ahead of the curve.

Should You Test Against WCAG 2.2?

For most organizations, the practical recommendation is:

Test against WCAG 2.1 AA as your compliance baseline. This satisfies Section 508 (which requires WCAG 2.0 AA, fully covered by 2.1 AA conformance) and ADA Title II (which explicitly requires WCAG 2.1 AA).

Evaluate the WCAG 2.2 additions for your specific product. Several of the new criteria, particularly Focus Not Obscured, Dragging Movements, Target Size, and Accessible Authentication, address real usability issues that affect your users regardless of legal requirements.

Include WCAG 2.2 criteria in new development. Even if your current compliance obligation is WCAG 2.1 AA, building new features to meet WCAG 2.2 criteria is forward-looking and reduces future remediation costs.

Update your ACR when ready. If your product conforms to WCAG 2.2 AA, document it. It differentiates your product in procurement evaluations and signals accessibility maturity.

Impact on Existing ACRs

If your current Accessibility Conformance Report was prepared against WCAG 2.0 or 2.1, it remains valid for its intended purpose. You are not required to retroactively test against WCAG 2.2 criteria.

However, when you next update your ACR, whether due to a product release, a recompete, or an annual refresh, consider expanding the evaluation to include WCAG 2.2 criteria. The VPAT 2.5 template already accommodates reporting against multiple WCAG versions.

Key Takeaways

  • WCAG 2.2 adds 9 new criteria focused on cognitive accessibility, mobile usability, and authentication
  • Section 508 currently references WCAG 2.0, but most agencies expect WCAG 2.1 AA in practice
  • ADA Title II explicitly requires WCAG 2.1 AA
  • Testing against WCAG 2.1 AA satisfies all current legal requirements
  • Incorporating WCAG 2.2 criteria into new development is a best practice that reduces future risk

Simkins & Elgazar conducts accessibility audits against WCAG 2.1 AA using DHS Trusted Tester methodology and can evaluate WCAG 2.2 criteria upon request. Contact us to discuss which standard applies to your compliance requirements.