A WCAG 2.2 accessibility audit is only as current as the checklist behind it — and most teams are still running the 2.1 list. WCAG 2.2 became a W3C Recommendation on October 5, 2023, added nine new success criteria, and removed one (4.1.1 Parsing). If your QA gate has not been re-pointed at 2.2, you are quietly failing criteria that regulators and litigants increasingly treat as the baseline.
The stakes are not abstract. The 2026 WebAIM Million report found that 95.9% of the top one million home pages had detectable WCAG failures, up from 94.8% a year earlier, with low-contrast text alone affecting 83.9% of pages. Detectable means an automated tool flagged it — and automation only sees part of the picture. The honest figure, from Deque's coverage study, is that tooling catches roughly 57% of accessibility issues by volume; the remainder needs a human at a keyboard and a screen reader.
This guide is built to be used, not just read. Below you will find the complete Level AA checklist mapped criterion-by-criterion to a one-line test method and its single most common failure, a clear line between what automation catches and what it cannot, the WCAG 2.2 criteria most auditors still miss, and the ADA and European Accessibility Act context that determines which version your clients are actually on the hook for.
- 01WCAG 2.2 added 9 criteria and removed 4.1.1 Parsing.Published as a W3C Recommendation in October 2023 (updated December 2024). Five of the nine additions sit at Level AA — the conformance bar most organisations target — so a 2.1-era checklist is now incomplete.
- 02Level AA means 56 cumulative criteria, not 87.WCAG 2.2 has 87 success criteria across all three levels (32 A + 24 AA + 31 AAA). Level AA conformance requires the 32 Level A plus the 24 Level AA criteria — 56 total. The 24 AA criteria are what this checklist covers.
- 03Automation catches roughly 57% of issues by volume.Per Deque's coverage study, axe-core surfaces about 57% of real-world issues by volume but only fully automates around 29.5% of WCAG 2.2 success criteria. Both figures are true; they measure different things, and conflating them is how teams over-trust a green Lighthouse score.
- 04The new criteria are mostly design decisions.Focus visibility, 24px target sizing, dragging alternatives, and authentication flows are architectural choices best handled before development, not patched during a late audit. Shift-left is cheaper than retrofit.
- 05Legal exposure tracks WCAG version by jurisdiction.The EAA is in force as of June 2025 but its harmonised standard still references WCAG 2.1; the US DOJ Title II rule names WCAG 2.1 Level AA with compliance dates extended into 2027–2028. Know which version each client is actually accountable to.
01 — The LandscapeWhy a 2.2 audit matters now.
Accessibility has moved from a nice-to-have to a measurable risk surface, and the gap between intent and execution is widening rather than closing. The WebAIM Million project automatically tests the home pages of the top one million websites every year; the 2026 report recorded an average of 56.1 detectable errors per page, up 10.1% year-over-year. That regression is not because the standard got harder — WCAG 2.2 is largely a superset of 2.1 — but because pages keep getting more complex.
The same report found home-page DOM complexity grew 22.5% in a year, and the average number of ARIA attributes per page climbed 27% to more than 133. That last number is the trap worth naming: more ARIA does not mean more accessible. Misapplied roles and states routinely introduce new failures that an automated scanner cannot catch and a screen-reader user trips over immediately. The teams shipping the most markup are often shipping the most defects.
Against that backdrop, re-pointing your audit at WCAG 2.2 is the cheapest reliability win available. The five new Level AA criteria are concrete and testable, the removal of 4.1.1 Parsing eliminates a criterion many auditors still waste time on, and the structure below turns a vague obligation into a checklist a QA engineer can run without an accessibility-specialist credential. Accessibility, like a front-end performance audit, belongs in your CI quality gate — not in a once-a-year scramble.
02 — What ChangedNine added, one removed since 2.1.
WCAG 2.2 introduced nine new success criteria and removed one. The removal matters as much as the additions: 4.1.1 Parsing is gone, because modern browsers handle malformed HTML robustly enough that the criterion became effectively obsolete. If your inherited 2.1 checklist still lists 4.1.1, you are spending audit time on a criterion that no longer applies — and any conformance claim that cites it needs updating.
Of the nine additions, five sit at Level AA, which is the bar most laws and clients target. Two more land at Level A. The remaining ones, including 2.4.13 Focus Appearance, are Level AAA and outside the scope of a standard AA audit. A common error in third-party checklists is promoting 2.4.13 to AA or demoting 2.5.7 Dragging Movements to AAA — both are wrong against the W3C source. The cards below summarise the additions that change your AA obligations.
Focus Not Obscured (2.4.11)
A focused component must not be entirely hidden by author content. The classic failure (F110) is a sticky header or footer that fully covers the element you just tabbed to. A scroll-padding-top buffer on the root element is the standard fix.
Dragging Movements (2.5.7)
Any function operated by dragging needs a single-pointer alternative unless dragging is essential. It does not apply to native browser scrolling. Range sliders need track-click support; sortable lists need up/down buttons.
Target Size (2.5.8)
Interactive targets must be at least 24×24 CSS pixels, or pass via spacing, inline-text, equivalent-control, or essential exceptions. The 44×44px figure people quote is the more generous AAA criterion (2.5.5), not this one.
Accessible Auth (3.3.8)
Authentication cannot require memorising or transcribing unless an alternative exists. Blocking paste in password fields is an explicit failure. Password managers and WebAuthn satisfy the criterion cleanly.
The two new Level A criteria are easy wins that audits frequently overlook. 3.3.7 Redundant Entry requires that information already supplied in a multi-step process be auto-populated or selectable rather than re-typed — the common failure is clearing valid form data after a validation error in a later step. 3.2.6 Consistent Help requires that help mechanisms (phone, chat, FAQ links) appear in the same relative order across pages; moving a live-chat widget from top-right on one page to bottom-left on another fails it. Both are cheap to satisfy and cheap to break during a redesign.
Most of the new criteria are best addressed during design, rather than later in development or testing.— Level Access, WCAG 2.2 compliance guidance
03 — The ChecklistThe 24-criterion Level AA reference.
This is the proprietary core of the guide: every Level AA success criterion that is unique to Level AA, each mapped to a one-line test method, its single most common failure, and whether automated tooling can fully evaluate it. Rows tagged NEW were introduced in WCAG 2.2 and are the ones a 2.1-era checklist will be missing. The 32 Level A criteria are also required for AA conformance but are not repeated here; this table isolates the AA-specific layer where most audit gaps live.
| SC | Criterion | How to test | Common failure | Auto |
|---|---|---|---|---|
| 1.2.4 | Captions (Live) | Play live audio/video; confirm real-time captions render. | Live streams shipped with no caption track. | No |
| 1.2.5 | Audio Description (Prerecorded) | Watch video with audio description enabled. | Visual-only information never narrated. | No |
| 1.3.4 | Orientation | Rotate device portrait↔landscape; confirm content adapts. | Layout locked to a single orientation. | No |
| 1.3.5 | Identify Input Purpose | Inspect form fields for autocomplete attributes. | Name / email inputs missing autocomplete tokens. | Partial |
| 1.4.3 | Contrast (Minimum) | Run a contrast checker on text vs background. | Body and link text below 4.5:1 ratio. | Yes |
| 1.4.4 | Resize Text | Zoom browser text to 200%; confirm no loss. | Content clipped or overlapping at 200% zoom. | Partial |
| 1.4.5 | Images of Text | Audit for text rendered as bitmap images. | Headings or CTAs baked into image files. | Partial |
| 1.4.10 | Reflow | View at 320px width; confirm no 2-axis scroll. | Horizontal scrollbar appears at mobile width. | Partial |
| 1.4.11 | Non-text Contrast | Check icon, border, and focus-ring contrast (3:1). | Form borders and toggle states below 3:1. | Partial |
| 1.4.12 | Text Spacing | Apply WCAG spacing bookmarklet; confirm readability. | Text overlaps when line height is increased. | No |
| 1.4.13 | Content on Hover or Focus | Hover tooltips; confirm dismissable, persistent, hoverable. | Tooltip vanishes before the pointer can reach it. | No |
| 2.4.5 | Multiple Ways | Confirm at least two routes to each page (nav + search/map). | Pages reachable only by a single deep link. | No |
| 2.4.6 | Headings and Labels | Review heading text and field labels for clarity. | Generic 'Section' headings or unlabeled controls. | Partial |
| 2.4.7 | Focus Visible | Tab through the page; confirm a visible focus indicator. | Default outline removed with outline:none and no replacement. | No |
| 2.4.11 | Focus Not Obscured (Minimum)New | Tab to elements near sticky headers; confirm none fully hidden. | Sticky header completely covers the focused element (F110). | No |
| 2.5.7 | Dragging MovementsNew | Find every drag UI; confirm a click/tap alternative exists. | Slider or sortable list operable only by dragging. | No |
| 2.5.8 | Target Size (Minimum)New | Measure interactive targets; confirm 24×24 CSS px or spacing. | Icon buttons under 24px with no surrounding spacing. | Partial |
| 3.1.2 | Language of Parts | Check lang attribute on foreign-language passages. | Mixed-language content with a single page-level lang. | Partial |
| 3.2.3 | Consistent Navigation | Compare nav order across templates. | Menu items reordered between page types. | No |
| 3.2.4 | Consistent Identification | Confirm repeated components share names/icons. | Same action labeled differently on different pages. | No |
| 3.3.3 | Error Suggestion | Trigger validation; confirm corrective guidance shown. | 'Invalid input' with no explanation of the fix. | No |
| 3.3.4 | Error Prevention (Legal/Financial) | On commit actions, confirm review/reverse/confirm step. | Irreversible payment submitted with no confirmation. | No |
| 3.3.8 | Accessible Authentication (Minimum)New | Audit login for cognitive-function tests; confirm an exception path. | Paste blocked in password fields; puzzle-only verification. | No |
| 4.1.3 | Status Messages | Trigger async updates; confirm an aria-live announcement. | Cart count or toast updates silently for screen readers. | Partial |
The Auto column is the part teams most often misread. "Yes" means a scanner can reliably determine pass/fail; "Partial" means it flags candidates but a human confirms; "No" means the criterion is effectively a manual judgment. Notice how many of the highest-value criteria — focus visibility, dragging alternatives, consistent navigation, error suggestion — sit at "No." That is not a tooling gap to be fixed later; it is the structural reason accessibility cannot be fully automated.
04 — AutomationWhat tooling actually catches.
Two numbers get quoted about automated accessibility testing, and they appear to contradict each other until you understand what each measures. The first: axe-core (the open-source engine from Deque, v4.11.4 as of April 2026) catches approximately 57% of accessibility issues by volume in real audits. The second: only about 29.5% of WCAG 2.2 success criteria are fully automatable, with another 10.3% partly covered and 60.2% requiring manual testing. Both are correct.
The reconciliation is that a small number of highly automatable criteria account for an outsized share of real-world defects. Per Deque's coverage data, contrast, language-of-page, and name/role/value together represent roughly 58.8% of all real accessibility issues by volume — and all three are categories automation handles well. So a scanner clears a huge fraction of the defect count while still touching only a minority of the criteria. Optimise for the wrong number and you either over-trust automation or dismiss it.
Automation coverage · issues by volume vs criteria count
Source: Deque Automated Accessibility Coverage ReportGoogle Lighthouse uses axe-core as its accessibility engine but runs a subset of the rules and produces a weighted 0–100 score, so in practice it catches a smaller share of real-world issues than running axe-core directly. The practical takeaway: a Lighthouse accessibility score of 100 is a floor, not a finish line. It confirms the automatable criteria pass; it says nothing about focus order, screen-reader semantics, or whether your drag interactions have a click alternative.
05 — Manual TestingThe passes a human has to run.
Focus management is the canonical example of why automation is not enough. Focus Order (2.4.3), Focus Visible (2.4.7), and Meaningful Sequence (1.3.2) are effectively 100% manual categories — no scanner reliably evaluates whether the focus path through your page makes sense to someone who cannot see it. These need a person tabbing through every interactive element, watching the indicator, and confirming the order matches the visual and logical flow.
The W3C WAI-ARIA Authoring Practices Guide (APG) defines the keyboard conventions complex widgets are expected to follow. The core rule: Tab and Shift+Tab move focus into and out of a composite widget, while arrow keys navigate within it — the "roving tabindex" pattern used by grids, trees, toolbars, and tab panels. If a custom component does not follow these conventions, no automated tool will tell you; a keyboard-only user will discover it in seconds. Teams building in React should bake these patterns into their components directly — see our Next.js accessibility considerations for where focus and ARIA work sits in a Server Components architecture.
Tab through everything
Operate the entire interface with keyboard only. Confirm every interactive element is reachable, the focus indicator is always visible, focus order is logical, and nothing becomes a keyboard trap. Focus Order and Focus Visible are not automatable.
Test on real assistive tech
Run the flows on at least one screen reader (NVDA, JAWS, or VoiceOver). Confirm names, roles, and states are announced correctly, status messages reach aria-live regions, and ARIA roles match actual behaviour rather than introducing new errors.
Resize and reflow
Zoom text to 200% and view at a 320px-wide viewport. Confirm no content is lost, no two-axis scrolling appears, and text spacing adjustments do not cause overlap. Tooling flags candidates here, but a human confirms readability.
06 — Common FailuresWhere real pages break most often.
The WebAIM Million 2026 report gives the most reliable picture of where accessibility actually fails at scale, because it tests real home pages rather than curated examples. Six failure categories dominate, and the striking part is that nearly all of them are automatable — meaning these are not subtle judgment calls, they are defects a scanner in CI would have caught before deploy.
Most common detectable WCAG failures · share of pages
Source: WebAIM Million 2026 (top 1M home pages)Low contrast is the standout, and not just because it tops the list at 83.9% of pages — it is because the figure rose from 79.1% the year before. Contrast is one of the most automatable criteria there is, yet its prevalence keeps climbing as design systems chase muted greys and ever-lighter placeholder text against white. The lesson is structural: a defect being automatable does nothing if the automation never runs in the pipeline. The single highest-leverage move for most teams is wiring axe-core into CI so these six categories simply cannot ship.
07 — Legal ContextWhich version each region actually enforces.
The most common compliance mistake is assuming "the law requires WCAG 2.2" everywhere. It does not — yet. Different regimes reference different versions, and conflating them leads to either over-engineering or a false sense of safety. The decision cards below map the major regimes to the WCAG version each currently enforces and the practical posture we recommend.
European Accessibility Act (EAA)
In force for new products and services since June 28, 2025, with existing ones due by June 28, 2030. Its harmonised standard, EN 301 549 v3.2.1, still incorporates WCAG 2.1 — a v4.1.1 update referencing WCAG 2.2 is expected but not yet published. Build to 2.1 as the legal floor.
ADA Title II (state & local government)
The DOJ final rule (April 2024) names WCAG 2.1 Level AA. Compliance dates were extended in 2026: entities serving 50,000+ people by April 26, 2027; smaller entities and special districts by April 26, 2028. This applies to government, not private business.
ADA Title III (private business)
No final federal web rule yet — courts apply a WCAG standard case-by-case. Federal Title III lawsuits totalled 8,667 in 2025, concentrated in California, Florida, and New York, with settlements commonly in the five-figure range plus fees. Conform to AA proactively.
Build to 2.2, document the version
Implement WCAG 2.2 Level AA across the board: it is a near-superset of 2.1, future-proofs against pending standard updates, and the new criteria are cheap when handled at design time. Then record in your conformance statement exactly which version each client is legally accountable to.
08 — The ProcessRunning the audit end to end.
A defensible audit is layered, not a single tool run. Start with the automated pass to clear the high-volume, high-automation defects — contrast, missing labels, empty controls, page language. Run axe-core (or a wrapper like Lighthouse) across representative templates rather than every URL, because most failures are template-level, not page-level. This pass alone should eliminate the bulk of the WebAIM Million top-six failures.
Then layer the manual passes the table marks as "No": a full keyboard traversal for focus order, visibility, and traps; a screen-reader pass for names, roles, states, and status messages; and a reflow-and-zoom check at 200% and 320px width. Finally, walk the new WCAG 2.2 criteria explicitly, since they are the ones a carried-over 2.1 checklist will silently skip — focus not obscured by sticky elements, 24px target sizing, dragging alternatives, accessible authentication, redundant entry, and consistent help.
This layering applies with extra force to commerce flows. The EAA scope explicitly includes e-commerce, and checkout is where the new criteria concentrate: redundant entry across multi-step forms, target sizing on quantity steppers, and accessible authentication at login. If you are auditing a store, fold accessibility into your broader ecommerce accessibility requirements review so the checkout path is tested as one system. For teams that want this operationalised as a recurring quality gate rather than a one-off, our web development engagements build accessibility testing directly into CI, and our broader AI digital transformation work covers the governance side for organisations standardising across many properties.
09 — ConclusionA checklist your team can actually run.
WCAG 2.2 conformance is an engineering discipline, not a one-time scan.
The gap the data exposes is not a knowledge gap — the standard is public and stable — it is an execution gap. When 95.9% of home pages still fail and the most common defect is the most automatable one, the problem is not that teams do not know what contrast is; it is that the checks never run where they would catch the defect. The fix is to treat accessibility the way mature teams already treat tests and performance budgets: a gate in the pipeline, not a memo after launch.
The path is concrete. Re-point your checklist at WCAG 2.2 Level AA, drop 4.1.1 Parsing, add the five new AA criteria and two new A criteria, wire axe-core into CI to clear the automatable majority of defects, and reserve human effort for the focus, screen-reader, and reflow passes that no tool can replace. Then document, per client, which version their jurisdiction actually enforces — because the answer in 2026 is still WCAG 2.1 in most binding regimes, even as 2.2 becomes the de facto build target.
Looking forward, the direction is unambiguous: EN 301 549 will eventually incorporate WCAG 2.2, US case law keeps treating AA conformance as the practical bar, and page complexity will keep pushing detectable error counts up unless automation moves left into the build. The teams that win the next two years are the ones that stop auditing for accessibility annually and start enforcing it on every commit.