Accessibility Is Now a Compliance Requirement: WCAG 2.2, the EAA and What to Fix First

For most of the last decade, accessibility was argued for on ethical and commercial grounds and deferred on budgetary ones. That argument has changed shape. The European Accessibility Act has applied to products and services placed on the EU market since June 2025, covering e-commerce, banking, e-books, transport and telecoms sold to consumers — and it applies on the basis of where your customers are, not where your company is registered. In the United States, the Department of Justice rule for state and local government services set an explicit WCAG standard with the first compliance deadline passing in April 2026. Accessibility has become a procurement question and a legal one.

The technical target is less confusing than it looks. The harmonised European standard, EN 301 549, points at WCAG Level AA, and WCAG 2.2 has been the current recommendation since late 2023. If you build to WCAG 2.2 Level AA you are meeting the substance of what these regimes ask for. WCAG 3.0 remains a working draft with a different conformance model, and it is not something to wait for or plan around — teams that have been holding off for it have now been holding off for years.

Two exemptions are worth knowing before you panic or relax. Microenterprises providing services — broadly fewer than ten staff and a small turnover — are outside the EAA's service obligations, though that exemption does not extend to manufacturers of products. And some contracts for services already in place before the deadline may continue for a transitional period. Neither exemption is a strategy: if you sell to enterprise or public sector customers, their procurement teams will ask for a conformance statement regardless of whether a regulator would.

The WCAG 2.2 criteria that catch existing sites out :

• Target Size — interactive controls need at least a 24 by 24 pixel target, which breaks a lot of dense icon toolbars
• Focus Not Obscured — sticky headers and cookie bars must not hide the element the keyboard has focused
• Dragging Movements — anything draggable needs a single-pointer alternative, so kanban boards and sliders need a fallback
• Accessible Authentication — no cognitive test such as transcribing a code from memory, and password managers must not be blocked
• Redundant Entry — do not ask the user to re-type information they have already given you in the same process
• Consistent Help — support and contact routes appear in the same relative place on every page

Automated scans are a floor, not a verdict

An automated checker will find missing alternative text, unlabelled form fields, insufficient contrast and broken heading structure, and it will find them cheaply and repeatably. What it cannot judge is whether the alternative text is meaningful, whether the focus order matches the visual order, whether a custom component announces its state correctly, or whether the error message tells a user how to fix the problem. Depending on the tool and the site, automation covers somewhere between a third and half of the criteria that matter. The rest needs a person with a keyboard and a screen reader, which is less daunting than it sounds: twenty minutes of tabbing through your main journey will surface more real problems than a week of arguing about tooling.

A remediation order that gets results

The design system is where this becomes economical. Fixing contrast, focus states, target sizes and form patterns page by page is endless; fixing them in the components every page is built from is finite. Teams with a shared component library typically resolve the majority of their automatable findings in a handful of pull requests, because the same button appears in four hundred places. Teams without one discover that accessibility remediation is really a design system project wearing a compliance hat.

It is also worth stating the part that has nothing to do with regulation. Accessible sites are more usable for everyone: they work with a keyboard, they survive a slow connection, they read correctly when a browser translates them, and they are structurally clearer to the crawlers and answer engines that now decide whether your content gets cited at all. Semantic markup, sensible heading hierarchy and meaningful link text are simultaneously accessibility work and technical SEO work.

If you need a first move this month, run an automated scan on your five most visited templates, then walk your primary conversion journey with the keyboard and a screen reader and write down every point where you got stuck. That list, in that order, is your roadmap — and it will be considerably shorter than the audit report you were dreading.