Compliance guide

WCAG 2.1 vs 2.2: What Changed and Do You Need to Update Your Site?

WCAG 2.2 became the W3C's official recommendation in October 2023. It added 9 new success criteria and deprecated one. If your site already meets WCAG 2.1 AA, the gap is real — but narrow. This guide explains what's new, what still applies, and what the law actually requires right now.

Not legal advice. ShipSafe identifies common risk patterns based on WCAG guidelines. This guide is educational and not a legal opinion. For a compliance determination that holds up in court, consult a qualified attorney.

What WCAG 2.2 actually added

WCAG 2.2 was published by the W3C on October 5, 2023. It is backwards-compatible with WCAG 2.1 — every criterion in 2.1 is still in 2.2, with one exception (4.1.1 Parsing, which was deprecated). The new version adds 9 new success criteria spread across three conformance levels. Here's the full list:

Success Criterion Level What it requires
2.4.11 Focus Not Obscured (Minimum) AA The focused component must not be entirely hidden behind sticky headers, footers, or cookie banners.
2.4.12 Focus Not Obscured (Enhanced) AAA No part of the focused component is obscured by any author-created content.
2.4.13 Focus Appearance AAA The focus indicator must meet minimum size and contrast requirements.
2.5.7 Dragging Movements AA All functionality that requires dragging must also be operable with a single pointer (click/tap).
2.5.8 Target Size (Minimum) AA Interactive targets must be at least 24×24 CSS pixels, or have sufficient offset spacing.
3.2.6 Consistent Help A If a help mechanism (contact form, chat, phone) appears on multiple pages, it must be in the same relative position on each.
3.3.7 Redundant Entry A Don't ask users to re-enter information they already provided in the same session or process.
3.3.8 Accessible Authentication (Minimum) AA Authentication must not require solving a cognitive function test (like image puzzles or distorted text) without providing an accessible alternative.
3.3.9 Accessible Authentication (Enhanced) AAA Authentication cannot require any cognitive function test, even with an alternative provided.

Targets for most sites: the five A and AA criteria. The three AAA criteria are not a universal conformance target — Level AAA is aspirational and applies to specific use cases.

The 5 new A/AA criteria, explained for typical sites

2.4.11 AA

Focus Not Obscured (Minimum)

When a user tabs to a focusable element — a button, a link, an input — the browser moves focus to it and renders a visible focus indicator. If your site has a sticky header, a sticky footer, a cookie consent banner, or any position-fixed element that covers the page, that element can completely hide the focused component from view. The criterion requires that the focused component is at least partially visible — not entirely obscured.

Who is affected: Any site with a sticky navigation bar, a "back to top" button pinned to the corner, or a cookie consent overlay. If you have a 70px sticky header and a focused button sits at the very top of the content area, keyboard users may not see which element has focus.

How to fix it: Add scroll-margin-top (or scroll-padding-top on the container) equal to the height of your sticky header. This offsets the browser's scroll position so focused elements are revealed below the fixed element:

/* Assuming a 70px sticky header */
:focus {
  scroll-margin-top: 80px; /* a bit more than the header height */
}

For cookie banners that appear at the bottom of the viewport, test that tabbing into form inputs at the bottom of the page doesn't hide them behind the banner. Most modern cookie-consent scripts handle this correctly — verify with keyboard-only navigation.

2.5.8 AA

Target Size (Minimum)

Every interactive component must have a target size of at least 24×24 CSS pixels. There's an exception: if the target is smaller than 24×24, it must have enough spacing around it so that a 24×24 bounding box centered on the target doesn't overlap any adjacent target. Inline text links are also exempt (the criterion doesn't expect you to make every word in a paragraph a large clickable zone).

Who is affected: Sites with icon-only buttons below 24px (hamburger menu, close X, social share icons, search icon), small pagination dots or arrows, or densely packed navigation link lists where link padding is minimal.

How to fix it: Padding is your friend — you don't need to change the icon size itself. Adding padding increases the clickable area without changing the visual design:

/* Icon button: 20px icon becomes a 40px target */
.icon-btn {
  padding: 10px;       /* 20px icon + 10px padding × 2 = 40px target */
  line-height: 0;
  display: inline-flex;
  align-items: center;
}

/* Social icon row: space them out so 24px offset zones don't overlap */
.social-link {
  padding: 8px;
  min-width: 24px;
  min-height: 24px;
}

Use browser DevTools to verify: right-click any small button → Inspect → check the computed height and width in the Layout panel. Numbers below 24px need padding added.

2.5.7 AA

Dragging Movements

If any feature on your site requires a dragging gesture — sliding a range input, reordering items in a list, dragging-to-scroll a carousel, resizing a panel — that same action must also be achievable with a single pointer action (a click or tap) without any dragging path. Users with motor disabilities may not be able to maintain a pressed drag without releasing accidentally.

Who is affected: Sites with drag-to-sort lists, range sliders, custom carousel scroll areas, split-pane resizers, or any custom drag-and-drop UI. Standard HTML <input type="range"> sliders satisfy this automatically (keyboard arrow keys work). Custom drag-to-reorder requires an alternative: arrow buttons, a keyboard interface, or a dropdown for selecting position.

Who is not affected: Most marketing sites, documentation sites, and SaaS tools without drag-and-drop interactions pass this criterion automatically — nothing to do.

3.3.7 A

Redundant Entry

If a multi-step process (a checkout flow, a multi-page form, an onboarding wizard) asks the user to enter information they already provided in a previous step, that information must be auto-populated or available for the user to select. Re-typing an email address on step 3 when you entered it on step 1 is a failure. The criterion applies within a single process, not across sessions.

Who is affected: Sites with multi-step checkout, onboarding flows, or multi-page forms. Shipping address pre-filling from a billing address (or the "same as billing" checkbox) is the canonical fix pattern. Single-page forms are not affected — the criterion only applies when the user has to move to a new page or step.

Who is not affected: Password confirmation fields are explicitly excluded — re-entering a password for confirmation purposes is permitted. Single-step forms, landing pages, and tools without multi-step processes don't need to do anything.

3.3.8 AA

Accessible Authentication (Minimum)

If your login or authentication flow includes a cognitive function test — solving an image puzzle, identifying objects from photos, transcribing distorted text (classic CAPTCHA) — you must either provide an alternative that doesn't require a cognitive function test, or the page must provide an object recognition tool or a personal content recognition mechanism.

In practice: reCAPTCHA v2 (the "I'm not a robot" checkbox with an image challenge fallback) may fail this criterion unless the audio alternative is enabled and working. reCAPTCHA v3 (invisible, score-based with no user-facing challenge) satisfies the criterion. Email magic links, passkeys, and SMS codes satisfy it by design — they don't require cognitive function tests. Password entry (even with copy-paste) is permitted.

Who is not affected: Sites with no login, no form-gating, and no CAPTCHA. This criterion doesn't apply to content without authentication.

3.2.6 A

Consistent Help

If your site provides a help mechanism — a contact form link, a phone number, a live chat widget, an FAQ link — and it appears on multiple pages, it must be in the same relative position in the layout on each page. A help chat pinned bottom-right on the homepage but absent on product pages would be a failure; so would a contact link in the footer on most pages but in the header nav on one page only.

Who is not affected: Sites without any help mechanism, and sites whose help links are consistently placed in the footer or header on every page. Most sites already satisfy this by convention — the footer "Contact" link appears on every page in the same footer position.

What was removed: SC 4.1.1 Parsing

WCAG 2.2 deprecated Success Criterion 4.1.1 (Parsing), which had previously required valid, well-formed HTML with unique element IDs and correct start/end tags. The W3C removed it because modern browsers auto-correct most malformed markup before rendering it — the criterion was no longer practically testable against actual user impact.

What this means: if your WCAG 2.1 audit flagged Parsing failures (duplicate IDs, unclosed tags, broken nesting), those are not 2.2 conformance failures. They're still worth fixing — duplicate IDs break JavaScript and can confuse assistive technologies — but a WCAG 2.2 audit won't count them against your conformance level.

US legal compliance currently references WCAG 2.1 Level AA, not 2.2. The DOJ finalized two rules in 2024: its April 2024 rule under Title II of the ADA (applying to state and local government websites and apps) and its July 2024 rule under Title III (applying to places of public accommodation, which federal courts have broadly held includes commercial websites open to the public). Both rules cite WCAG 2.1 AA as the technical standard.

For private businesses facing ADA demand letters, the relevant bar is WCAG 2.1 Level AA. Most accessibility complaints and lawsuits use this standard as their benchmark.

That said: the W3C's current published recommendation is WCAG 2.2. If you're building a new site or undergoing a full accessibility remediation, targeting WCAG 2.2 AA is the more future-proof choice — the incremental work over 2.1 AA is modest for most sites, and the standard will migrate eventually. Sites already compliant with 2.1 AA should audit the five new A/AA criteria above; most will find only one or two require actual changes.

The fastest path if you've already addressed WCAG 2.1 AA: check for a sticky header hiding focused elements (2.4.11), audit any icon buttons under 24px (2.5.8), and confirm your login flow doesn't use an inaccessible CAPTCHA (3.3.8). For most marketing and SaaS sites, those three checks cover the meaningful gap between 2.1 and 2.2.

Check your site with ShipSafe

ShipSafe scans your page's HTML for the accessibility and privacy failures that appear most frequently in ADA demand letters — missing lang attribute, unlabeled form inputs, images without alt text, contrast failures, missing skip navigation, and no privacy policy link. Run it after making changes to confirm your fixes are in the markup, not just visually apparent.

Check my site with ShipSafe →

Also see: WCAG compliance for AI-generated sites — the 5 most-flagged gaps and how to fix them.

Frequently asked questions

Does the law require WCAG 2.1 or WCAG 2.2?

US law currently references WCAG 2.1 Level AA. The DOJ's April 2024 final rule for Title II (state and local government websites) and its July 2024 rule for Title III (places of public accommodation, which courts have extended to commercial websites) both cite WCAG 2.1 AA. Most ADA lawsuits targeting private businesses use 2.1 AA as the benchmark. That said, WCAG 2.2 is the current W3C recommendation and future-proofing your site to 2.2 AA is the better long-term choice — the gap from 2.1 is small.

If my site passes WCAG 2.1 AA, is it also WCAG 2.2 AA compliant?

Not automatically. WCAG 2.2 adds five new Level A and AA criteria not present in 2.1: Focus Not Obscured, Dragging Movements, Target Size (Minimum), Redundant Entry, and Accessible Authentication. A 2.1 AA-passing site needs to be checked against these five criteria to be considered 2.2 AA compliant. For most marketing sites and typical SaaS tools, the practical gap is focus management with sticky headers and small icon button sizes — both are quick CSS fixes.

What is the 24×24 pixel target size rule in WCAG 2.2?

Success Criterion 2.5.8 (Target Size Minimum) requires interactive UI components to have a target size of at least 24×24 CSS pixels, OR sufficient offset spacing so that a 24×24 bounding box centered on the target doesn't intersect adjacent targets. Common failures: icon-only buttons (hamburger menu, close X, social icons) under 24px, small pagination dots, and dense navigation links with minimal padding. The fix is almost always adding padding to the element, not changing the icon size itself.

What does WCAG 2.2 say about CAPTCHAs and login?

Success Criterion 3.3.8 (Accessible Authentication Minimum) prohibits requiring users to solve a cognitive function test — visual puzzles, distorted text transcription, object identification from photos — as the only authentication mechanism, unless an accessible alternative or aid is provided. In practice: reCAPTCHA v2's image challenge may fail without an active audio alternative. reCAPTCHA v3 (invisible, score-based), email magic links, passkeys, and SMS codes satisfy the criterion. Standard password entry is explicitly permitted.

Is WCAG 4.1.1 Parsing still required in WCAG 2.2?

No. WCAG 2.2 deprecated SC 4.1.1 (Parsing), which had required valid, well-formed HTML with no duplicate IDs and correct tag nesting. The rationale: modern browsers auto-repair most malformed markup, making the criterion effectively untestable against real user impact. Duplicate IDs and broken nesting are still bad practice and should be fixed — but they are no longer a formal WCAG 2.2 conformance failure. If your 2.1 audit flagged Parsing issues, they don't carry over to a 2.2 evaluation.

Which WCAG 2.2 changes matter most for a typical SaaS or marketing site?

In rough order of likely impact: (1) Target Size (2.5.8 AA) — small icon buttons and pagination dots appear on almost every site; (2) Focus Not Obscured (2.4.11 AA) — sites with sticky headers need scroll-margin-top to reveal focused elements; (3) Accessible Authentication (3.3.8 AA) — if your login uses reCAPTCHA v2, verify the audio alternative is working. The remaining criteria (Dragging Movements, Redundant Entry, Consistent Help) only apply if your site actually has those interaction patterns.

Also in the Copper Bay Labs ship-safety suite

WCAG compliance is one layer of pre-launch risk. These free tools cover the rest: