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AWE Education & Outreach · March 17, 2026

ADA Web Accessibility
Compliance

Everything water districts, landscaping companies, and public entities need to know — who must comply, what the spec requires, when the deadlines hit, and what happens if you don't.

Section 01

Applicability & Scope

0+

special districts nationwide must comply

Source: U.S. Census Bureau, 2022 Census of Governments (39,555 special district governments)

Title I — Employment

Employers with 15+ employees must provide reasonable accommodations for qualified individuals with disabilities in all aspects of employment — hiring, promotion, job assignments, training, and benefits. This includes accessible internal tools, intranets, and HR portals. Enforced by the EEOC.

42 U.S.C. §§ 12111–12117

Title II — Government

All state and local government entities — cities, counties, water districts, sewer districts, irrigation districts, transit authorities, school districts. The DOJ's April 2024 final rule names special districts explicitly.

42 U.S.C. §§ 12131–12165

Title III — Private Business

12 categories of "public accommodations" — hotels, restaurants, banks, healthcare, landscaping companies, contractors, nurseries, professional services. No minimum employee count. No revenue threshold. No small business exemption.

42 U.S.C. §§ 12181–12189

Critical Facts

  • 77% of lawsuits target companies under $25M revenue (UsableNet 2024 Mid-Year Report)
  • You cannot contract away liability — if a vendor builds your site, you are still liable (28 CFR § 35.130)
  • • The organization is liable, not individual employees (42 U.S.C. § 12132)

Exemptions (Very Narrow)

  • • Religious organizations (Title III only)
  • • Bona fide private clubs
  • • Purely personal non-commercial websites
  • No small business exemption exists

What's Covered

The rule applies to all digital content your organization publishes or maintains.

Websites
All pages
Mobile Apps
iOS & Android
Bill Pay
Online portals
Forms
Service requests, signups
PDFs
Rate schedules, minutes
Video
Board meetings, how-tos
Email
Newsletters
Social Media
Posts after deadline

Section 03

Deadlines & Consequences

Special District Deadline

April 26, 2027

Countdown to April 26, 2027 deadline

EntityDeadline
Large state/local govt (50K+ pop)April 24, 2026
Small state/local govt (under 50K)April 26, 2027
Special districts (water, sewer, etc.) — any sizeApril 26, 2027
Private businesses (Title III)No deadline — lawsuits are happening now

What's at Stake

First violation penalty (Title II) — 28 CFR § 85.5, adjusted Jan 2024

$0

Up to $230,464 for subsequent violations. State laws can add $4,000–$75,000+ per violation per visit.

0+

federal ADA web lawsuits filed in 2024

UsableNet 2024 Year-End Report

$0

average settlement

Seyfarth Shaw ADA Title III Report 2024

0K+

government entities affected

managing 109K+ websites and 8,800+ apps

The Carrot

  • 26% of U.S. adults (61M+ people) have some form of disability (CDC, 2023)
  • • Accessible sites get better SEO — proper headings, alt text, semantic HTML (W3C WAI, Business Case)
  • Curb-cut effect — captions in noisy rooms, high contrast in sunlight, keyboard nav for power users

Serial Litigation — It's a Business Model

  • 16 law firms account for 90%+ of all ADA web lawsuits (UsableNet 2024)
  • • One individual filed 312 lawsuits since 2022 (ADA Title III News & Insights)
  • 25% of lawsuits cited accessibility overlays as barriers — overlays attract litigation (UsableNet 2024)
WARNING

Overlay Tools

accessiBe, UserWay, AudioEye — these are a liability, not a solution.

$0

FTC fine against accessiBe (Jan 2025) for deceptive claims that its AI product could make websites ADA compliantSource: FTC Press Release, Jan 2025

0

companies using overlays were sued in 2024 — that's 25% of all ADA web lawsuitsSource: UsableNet 2024 Year-End Report

  • 600+ accessibility professionals signed an open letter opposing overlays (overlayfactsheet.com, 2021)
  • National Federation of the Blind formally opposes all overlays (NFB Resolution 2021-01)
  • Overlays cosmetically patch surface issues while leaving structural violations untouched
  • Some overlays break assistive technology that was previously working
  • Courts have consistently rejected "we installed an overlay" as a defense
“If a vendor pitches you an overlay as an ADA solution, run.”

Section 05

Tools

No single tool catches everything. Layer automated + AI + manual testing.

WAVE

Free

Browser Extension

Color-coded overlays showing errors, alerts, and features directly on the page. Data stays in browser.

Lighthouse

Free

Chrome DevTools

Built into Chrome. Quick 0-100 accessibility score. One-click audit.

axe DevTools

Free / $500yr

Browser Extension

Developer-focused. Code-level fixes. Powers most automated testing pipelines.

AI (Claude, ChatGPT)

Varies

Chat / API

Paste code, get WCAG evaluation. Generate accessible patterns. Can't test interactive behaviors.

Descript

$24/mo

Video Editor

AI auto-captioning at ~95% accuracy. Great starting point, but always requires human review for WCAG.

NVDA / VoiceOver

Free

Screen Readers

Manual testing with real assistive tech. NVDA (Windows) has 65.6% market share. VoiceOver built into Mac/iOS.

WAVE Icon Legend

Errors
Must fix
Alerts
Review needed
Features
Good practices
Structural
Headings, ARIA
Contrast
Ratio failures

Section 06

Scoring

Conformance is technically binary — pass or fail

Fail one success criterion on a page and that page does not conform. No partial credit, no percentage score. But the legal reality is more nuanced than the technical standard.

How WCAG 2.2 Level AA Conformance Is Determined

WCAG organizes requirements into 4 principles (Perceivable, Operable, Understandable, Robust), each containing guidelines, which contain individual success criteria. Each criterion is assigned a level:

Level A32 criteria

Bare minimum. Without these, content is fundamentally inaccessible.

Level AA24 criteria

The legal target. Addresses the most common barriers for the widest range of disabilities.

Level AAA31 criteria

Aspirational. Not required by law — impractical for all content types.

To conform at Level AA, a page must satisfy all 56 success criteria at levels A and AA (32 + 24). One failure on one criterion = the page does not conform. There is no percentage score — automated tools that show “85% compliant” are measuring detectable issues, not true conformance.

What Automated Scores Actually Measure

Automated tools can only detect ~30–40% of WCAG criteria. They catch missing alt text, broken labels, and contrast ratios — but cannot evaluate whether alt text is meaningful, whether focus order is logical, or whether content is understandable. Every “score” you see is a proxy, not a conformance determination.

Lighthouse Accessibility Score

Runs ~50 axe-core rules against the page. Returns a weighted 0–100 score. Higher weight for critical issues (missing labels, ARIA misuse).

A 100 does NOT mean AA conformant — it means zero detectable automated failures.

WAVE Error/Alert Count

Counts discrete violations and warnings per page. No composite score — just raw counts by category (errors, alerts, contrast, structural).

Zero errors is necessary but not sufficient. Alerts and manual checks still required.

axe-core / axe DevTools

Rule-based engine (powers Lighthouse and many CI tools). Returns pass/fail/incomplete per rule. Tags each rule with its WCAG criterion.

~57 rules map to WCAG AA. "Incomplete" results need manual review — they are not passes.

Pa11y / Tenon / Sortsite

Vary in approach — some crawl entire sites, some test single pages. Most return issue counts grouped by WCAG criterion and severity.

Site-wide crawls are valuable for catching patterns, but still limited to machine-detectable criteria.

How Courts Evaluate Compliance

FactorWeight
Number and severity of violationsHigh
Whether core services are blockedVery high
Documented accessibility programSignificant mitigator
Remediation timeline and progressSignificant mitigator
Responsiveness to complaintsMatters
Pattern vs. isolated violationsMatters

Good Faith — Not a Defense, But It Shapes Outcomes

The DOJ has explicitly said good faith will not excuse noncompliance. However, entities with documented programs get case dismissals, reduced settlements, and shorter timelines. Think of it like OSHA — a safety program doesn't prevent a violation, but it determines whether you get a warning or a six-figure fine.

  1. 1Adopt a formal accessibility policy
  2. 2Conduct regular audits (at least annually)
  3. 3Create a remediation plan with deadlines
  4. 4Train staff who create web content
  5. 5Publish an accessibility statement
  6. 6Respond promptly to accommodation requests
  7. 7Budget for accessibility as recurring line item
  8. 8Document everything

See it in action

We built a fake water district website with 13 intentional WCAG violations. Try finding and fixing them with a live code editor.

Sources & Citations

U.S. Census Bureau. “2022 Census of Governments.” 39,555 special district governments nationwide. census.gov/programs-surveys/cog

DOJ. “Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities.” 28 CFR Part 35, Final Rule, April 24, 2024. ~91,489 entities, 109,893 websites, 8,805 apps. ada.gov/resources/2024-03-08-web-rule

W3C. “Web Content Accessibility Guidelines (WCAG) 2.2.” W3C Recommendation, October 5, 2023. w3.org/TR/WCAG22

WebAIM. “The WebAIM Million — 2025 Annual Accessibility Analysis.” 96.3% of home pages had detectable WCAG 2 failures, avg 56.8 errors per page. webaim.org/projects/million

UsableNet. “2024 Year-End ADA Digital Accessibility Lawsuit Report.” 4,600+ federal lawsuits; 77% target companies under $25M; 25% of defendants used overlays. blog.usablenet.com

Seyfarth Shaw LLP. “ADA Title III News & Insights — 2024 Federal Lawsuit Statistics.” Average settlement data. adatitleiii.com

FTC. Press Release re: accessiBe $1M settlement, January 2025. ftc.gov/news-events

CDC. “Disability Impacts All of Us.” 26% of U.S. adults (61M+). cdc.gov

NFB. Resolution 2021-01: Regarding Accessibility Overlays. nfb.org/about-us/nfb-resolutions

Overlay Fact Sheet. Signed by 700+ accessibility practitioners. overlayfactsheet.com

DOJ Civil Rights Division. 28 CFR § 85.5 — Civil monetary penalties inflation adjustment. First violation: $75,000–$150,000; subsequent: up to $230,464 (2024 adjusted).

Importance ratings (6 Critical, 3 High, 4 Moderate) are editorial assessments based on WebAIM Million failure frequency, UsableNet/Seyfarth Shaw lawsuit citation data, and DOJ settlement patterns. “Critical” = most litigated and most frequently failed; “High” = frequently cited in audits and settlements; “Moderate” = important but less commonly the basis for legal action or situational in applicability.

SimplyScapes Labs · AWE Education & Outreach · March 17, 2026

Section 02

The Standard: WCAG 2.2 AA

0.0%

of the top 1 million websites fail WCAG — average of 56.8 errors per homepage

Source: WebAIM Million 2025 Annual Report

The Standard: WCAG 2.2 Level AA — Four Principles (POUR)

P
Perceivable
Alt text, captions, 4.5:1 contrast
O
Operable
Keyboard access, no traps, skip nav
U
Understandable
Language declared, predictable nav, error help
R
Robust
Proper semantics, ARIA, works with assistive tech

WCAG 2.2 Level AA — Section by Section

55 success criteria across 13 guidelines, plus Section 5 conformance requirements. WCAG 2.2 (Oct 2023) adds 6 new A/AA criteria and retires 4.1.1 Parsing. Each section below is collapsed — expand to see criteria, common failures, and live examples.

P

Principle 1: Perceivable

Information must be presentable in ways users can perceive — 20 criteria

1.1Text AlternativesCriticalExample1 criterion

Provide text alternatives for any non-text content so it can be changed into other forms people need.

A1.1.1 Non-text Content

All images, icons, SVGs, and non-text elements need text alternatives.

Common failures:

  • Images missing alt attributes entirely
  • Decorative images not marked with alt=""
  • Icon buttons (hamburger, close, search) with no accessible name
Missing Alt Text — SC 1.1.1
×No alt attribute
<img src="drip-emitter.jpg">
Descriptive alt text
<img src="drip-emitter.jpg"
     alt="A drip emitter watering
     a rose bush">
Rendered Preview

Screen reader announces:

"drip-emitter.jpg, image"

Screen reader announces:

"A drip emitter watering a rose bush, image"

W3C 2.2 Normative Text

1.1.1 Non-text Content (Level A)

All non-text content that is presented to the user has a text alternative that serves the equivalent purpose, except for the situations listed below.

Controls, Input: If non-text content is a control or accepts user input, then it has a name that describes its purpose.

Time-Based Media: If non-text content is time-based media, then text alternatives at least provide a descriptive identification of the non-text content.

Test: If non-text content is a test or exercise that would be invalid if presented in text, then text alternatives at least provide a descriptive identification of the non-text content.

Sensory: If non-text content is primarily intended to create a specific sensory experience, then text alternatives at least provide a descriptive identification of the non-text content.

CAPTCHA: If the purpose of non-text content is to confirm that content is being accessed by a person rather than a computer, then text alternatives that identify and describe the purpose of the non-text content are provided, and alternative forms of CAPTCHA using output modes for different types of sensory perception are provided to accommodate different disabilities.

Decoration, Formatting, Invisible: If non-text content is pure decoration, is used only for visual formatting, or is not presented to users, then it is implemented in a way that it can be ignored by assistive technology.
View 1.1.1 on W3C
1.2Time-based MediaModerateExample5 criteria

Provide alternatives for time-based media — captions, transcripts, and audio descriptions.

A1.2.1 Audio-only & Video-only
A1.2.2 Captions (Prerecorded)
A1.2.3 Audio Description or Alt
AA1.2.4 Captions (Live)
AA1.2.5 Audio Description

Common failures:

  • Videos with no captions or auto-generated captions never reviewed
  • Live-streamed board meetings with no real-time captioning
  • Podcast episodes with no transcript
Missing Captions — SC 1.2.2
×No captions track
<video src="board-meeting.mp4"
       controls>
</video>
Captions track included
<video src="board-meeting.mp4"
       controls>
  <track kind="captions"
    src="meeting-captions.vtt"
    srclang="en" label="English"
    default />
</video>
Rendered Preview
board-meeting.mp4

Deaf/hard-of-hearing users cannot access content

board-meeting.mp4CC

Synchronized captions available

W3C 2.2 Normative Text

1.2.1 Audio-only and Video-only (Prerecorded) (Level A)

For prerecorded audio-only and prerecorded video-only media, the following are true, except when the audio or video is a media alternative for text and is clearly labeled as such:

Prerecorded Audio-only: An alternative for time-based media is provided that presents equivalent information for prerecorded audio-only content.

Prerecorded Video-only: Either an alternative for time-based media or an audio track is provided that presents equivalent information for prerecorded video-only content.
View 1.2.1 on W3C ↗

1.2.2 Captions (Prerecorded) (Level A)

Captions are provided for all prerecorded audio content in synchronized media, except when the media is a media alternative for text and is clearly labeled as such.
View 1.2.2 on W3C ↗

1.2.3 Audio Description or Media Alternative (Prerecorded) (Level A)

An alternative for time-based media or audio description of the prerecorded video content is provided for synchronized media, except when the media is a media alternative for text and is clearly labeled as such.
View 1.2.3 on W3C ↗

1.2.4 Captions (Live) (Level AA)

Captions are provided for all live audio content in synchronized media.
View 1.2.4 on W3C ↗

1.2.5 Audio Description (Prerecorded) (Level AA)

Audio description is provided for all prerecorded video content in synchronized media.
View 1.2.5 on W3C ↗
1.3AdaptableCriticalExample5 criteria

Create content that can be presented in different ways without losing information or structure.

A1.3.1 Info and Relationships
A1.3.2 Meaningful Sequence
A1.3.3 Sensory Characteristics
AA1.3.4 Orientation
AA1.3.5 Identify Input Purpose

Common failures:

  • Styled divs used instead of proper heading tags
  • Form inputs without associated label elements
  • Required fields indicated only by color with no programmatic indication
Non-Semantic Headings — SC 1.3.1
×Styled divs — no semantic structure
<div class="big-bold-text">
  Service Area Map
</div>
<div class="section-content">
  Coverage includes...
</div>
Proper heading hierarchy
<h2>Service Area Map</h2>
<section>
  <p>Coverage includes...</p>
</section>
Rendered Preview

Service Area Map

Screen reader sees flat text — no heading structure to navigate

Service Area Map

Screen reader: "heading level 2, Service Area Map" — navigable

W3C 2.2 Normative Text

1.3.1 Info and Relationships (Level A)

Information, structure, and relationships conveyed through presentation can be programmatically determined or are available in text.
View 1.3.1 on W3C ↗

1.3.2 Meaningful Sequence (Level A)

When the sequence in which content is presented affects its meaning, a correct reading sequence can be programmatically determined.
View 1.3.2 on W3C ↗

1.3.3 Sensory Characteristics (Level A)

Instructions provided for understanding and operating content do not rely solely on sensory characteristics of components such as shape, color, size, visual location, orientation, or sound.
View 1.3.3 on W3C ↗

1.3.4 Orientation (Level AA)

Content does not restrict its view and operation to a single display orientation, such as portrait or landscape, unless a specific display orientation is essential.
View 1.3.4 on W3C ↗

1.3.5 Identify Input Purpose (Level AA)

The purpose of each input field collecting information about the user can be programmatically determined when the input field serves a purpose identified in the Input Purposes for User Interface Components section, and the content is implemented using technologies with support for identifying the expected meaning for form input data.
View 1.3.5 on W3C ↗
1.4DistinguishableCriticalExample9 criteria

Make it easier for users to see and hear content — contrast, resize, spacing, and visual presentation.

A1.4.1 Use of Color
A1.4.2 Audio Control
AA1.4.3 Contrast (Minimum)
AA1.4.4 Resize Text
AA1.4.5 Images of Text
AA1.4.10 Reflow
AA1.4.11 Non-text Contrast
AA1.4.12 Text Spacing
AA1.4.13 Content on Hover/Focus

Common failures:

  • Light gray text on white backgrounds — the single most common WCAG failure
  • Fixed-height containers that clip text at 200% zoom
  • Form input borders that blend into the background
Low Contrast Text — SC 1.4.3
×Fails 4.5:1 ratio
<p style="color: #a8c8e8;
         background: #ffffff;">
  Light blue on white (2.1:1)
</p>
Passes 4.5:1 ratio
<p style="color: #2d5f8a;
         background: #ffffff;">
  Dark blue on white (6.8:1)
</p>
Rendered Preview

Light blue on white (2.1:1)

Contrast ratio: 2.1:1 — FAIL

Dark blue on white (6.8:1)

Contrast ratio: 6.8:1 — PASS

W3C 2.2 Normative Text

1.4.1 Use of Color (Level A)

Color is not used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.
View 1.4.1 on W3C ↗

1.4.2 Audio Control (Level A)

If any audio on a Web page plays automatically for more than 3 seconds, either a mechanism is available to pause or stop the audio, or a mechanism is available to control audio volume independently from the overall system volume level.
View 1.4.2 on W3C ↗

1.4.3 Contrast (Minimum) (Level AA)

The visual presentation of text and images of text has a contrast ratio of at least 4.5:1, except for the following:

Large Text: Large-scale text and images of large-scale text have a contrast ratio of at least 3:1.

Incidental: Text or images of text that are part of an inactive user interface component, that are pure decoration, that are not visible to anyone, or that are part of a picture that contains significant other visual content, have no contrast requirement.

Logotypes: Text that is part of a logo or brand name has no contrast requirement.
View 1.4.3 on W3C ↗

1.4.4 Resize Text (Level AA)

Except for captions and images of text, text can be resized without assistive technology up to 200 percent without loss of content or functionality.
View 1.4.4 on W3C ↗

1.4.5 Images of Text (Level AA)

If the technologies being used can achieve the visual presentation, text is used to convey information rather than images of text except for Customizable (the image of text can be visually customized to the user's requirements) and Essential (a particular presentation of text is essential to the information being conveyed).
View 1.4.5 on W3C ↗

1.4.10 Reflow (Level AA)

Content can be presented without loss of information or functionality, and without requiring scrolling in two dimensions for: Vertical scrolling content at a width equivalent to 320 CSS pixels; Horizontal scrolling content at a height equivalent to 256 CSS pixels. Except for parts of the content which require two-dimensional layout for usage or meaning.
View 1.4.10 on W3C ↗

1.4.11 Non-text Contrast (Level AA)

The visual presentation of the following have a contrast ratio of at least 3:1 against adjacent color(s): User Interface Components (visual information required to identify user interface components and states) and Graphical Objects (parts of graphics required to understand the content).
View 1.4.11 on W3C ↗

1.4.12 Text Spacing (Level AA)

In content implemented using markup languages that support the following text style properties, no loss of content or functionality occurs by setting all of the following and by changing no other style property: Line height (line spacing) to at least 1.5 times the font size; Spacing following paragraphs to at least 2 times the font size; Letter spacing (tracking) to at least 0.12 times the font size; Word spacing to at least 0.16 times the font size.
View 1.4.12 on W3C ↗

1.4.13 Content on Hover or Focus (Level AA)

Where receiving and then removing pointer hover or keyboard focus triggers additional content to become visible and then hidden, the following are true: Dismissible (a mechanism is available to dismiss the additional content without moving pointer hover or keyboard focus), Hoverable (if pointer hover can trigger the additional content, then the pointer can be moved over the additional content without the additional content disappearing), and Persistent (the additional content remains visible until the hover or focus trigger is removed, the user dismisses it, or its information is no longer valid).
View 1.4.13 on W3C ↗
O

Principle 2: Operable

UI components and navigation must be operable by all users — 20 criteria

2.1Keyboard AccessibleCriticalExample3 criteria

Make all functionality available from a keyboard — no mouse required.

A2.1.1 Keyboard
A2.1.2 No Keyboard Trap
A2.1.4 Character Key Shortcuts

Common failures:

  • Custom dropdowns, sliders, and carousels that only respond to mouse clicks
  • Modal dialogs that trap focus without cycling back to the beginning
  • onClick handlers on divs without keyboard event handlers or tabindex
Non-Keyboard Button — SC 2.1.1
×Div with onclick — not keyboard accessible
<div class="btn"
     onclick="submit()">
  Pay Bill
</div>
Native button — keyboard accessible by default
<button type="button"
        onclick="submit()">
  Pay Bill
</button>
Rendered Preview
Pay Bill

Tab key skips this — keyboard users cannot pay their bill

Focusable, Enter/Space activates — works for all users

W3C 2.2 Normative Text

2.1.1 Keyboard (Level A)

All functionality of the content is operable through a keyboard interface without requiring specific timings for individual keystrokes, except where the underlying function requires input that depends on the path of the user's movement and not just the endpoints.
View 2.1.1 on W3C ↗

2.1.2 No Keyboard Trap (Level A)

If keyboard focus can be moved to a component of the page using a keyboard interface, then focus can be moved away from that component using only a keyboard interface, and, if it requires more than unmodified arrow or tab keys or other standard exit methods, the user is advised of the method for moving focus away.
View 2.1.2 on W3C ↗

2.1.4 Character Key Shortcuts (Level A)

If a keyboard shortcut is implemented in content using only letter (including upper- and lower-case letters), punctuation, number, or symbol characters, then at least one of the following is true: Turn off (a mechanism is available to turn the shortcut off), Remap (a mechanism is available to remap the shortcut to include one or more non-printable keyboard keys), Active only on focus (the keyboard shortcut for a user interface component is only active when that component has focus).
View 2.1.4 on W3C ↗
2.2Enough TimeModerateExample2 criteria

Give users enough time to read and use content. Time limits must be adjustable or extendable, and auto-updating content must be pausable.

A2.2.1 Timing Adjustable
A2.2.2 Pause, Stop, Hide

Common failures:

  • Session timeouts with no warning or extension option
  • Auto-scrolling news tickers or carousels with no pause button
  • Auto-refreshing pages that reset user position
Auto-Moving Content — SC 2.2.2
×Auto-scrolling with no pause control
<div class="news-ticker"
     style="animation: scroll
     10s infinite">
  Water conservation alert...
</div>
Pause control provided
<div class="news-ticker"
     role="marquee"
     aria-live="off">
  Water conservation alert...
  <button aria-label="Pause
    news ticker">Pause</button>
</div>
W3C 2.2 Normative Text

2.2.1 Timing Adjustable (Level A)

For each time limit that is set by the content, at least one of the following is true: Turn off (the user is allowed to turn off the time limit before encountering it), Adjust (the user is allowed to adjust the time limit before encountering it over a wide range that is at least ten times the length of the default setting), Extend (the user is warned before time expires and given at least 20 seconds to extend the time limit with a simple action, and the user is allowed to extend the time limit at least ten times).
View 2.2.1 on W3C ↗

2.2.2 Pause, Stop, Hide (Level A)

For moving, blinking, scrolling, or auto-updating information, all of the following are true:

Moving, blinking, scrolling: For any moving, blinking or scrolling information that (1) starts automatically, (2) lasts more than five seconds, and (3) is presented in parallel with other content, there is a mechanism for the user to pause, stop, or hide it unless the movement, blinking, or scrolling is part of an activity where it is essential.

Auto-updating: For any auto-updating information that (1) starts automatically and (2) is presented in parallel with other content, there is a mechanism for the user to pause, stop, or hide it or to control the frequency of the update unless the auto-updating is part of an activity where it is essential.
View 2.2.2 on W3C ↗
2.3Seizures & Physical ReactionsModerate1 criterion

Do not design content in a way that is known to cause seizures or physical reactions. Approximately 3% of people with epilepsy have photosensitive epilepsy (Epilepsy Foundation).

A2.3.1 Three Flashes or Below Threshold

No content flashes more than 3 times per second.

Common failures:

  • Animated GIFs or videos with rapid flashing or strobing effects
  • Rapid CSS transitions that create a flashing effect
  • Embedded third-party ads with flashing content
W3C 2.2 Normative Text

2.3.1 Three Flashes or Below Threshold (Level A)

Web pages do not contain anything that flashes more than three times in any one second period, or the flash is below the general flash and red flash thresholds.
View 2.3.1 on W3C ↗
2.4NavigableCriticalExample8 criteria

Help users navigate, find content, and determine where they are.

A2.4.1 Bypass Blocks
A2.4.2 Page Titled
A2.4.3 Focus Order
A2.4.4 Link Purpose (In Context)
AA2.4.5 Multiple Ways
AA2.4.6 Headings and Labels
AA2.4.7 Focus Visible
AA2.4.11 Focus Not Obscured2.2

Common failures:

  • No "skip to main content" link
  • CSS outline: none applied globally with no replacement focus style
  • Links that say only "Click here" or "Read more" with no context
Non-Descriptive Link Text — SC 2.4.4
×"Click here" means nothing out of context
<a href="/tips">Click here</a>
Descriptive and meaningful
<a href="/tips">View water
  conservation tips</a>
Rendered Preview

For water conservation tips, Click here.

Link list shows: "Click here" — meaningless without surrounding text

View water conservation tips

Link list shows: "View water conservation tips" — self-describing

W3C 2.2 Normative Text

2.4.1 Bypass Blocks (Level A)

A mechanism is available to bypass blocks of content that are repeated on multiple Web pages.
View 2.4.1 on W3C ↗

2.4.2 Page Titled (Level A)

Web pages have titles that describe topic or purpose.
View 2.4.2 on W3C ↗

2.4.3 Focus Order (Level A)

If a Web page can be navigated sequentially and the navigation sequences affect meaning or operation, focusable components receive focus in an order that preserves meaning and operability.
View 2.4.3 on W3C ↗

2.4.4 Link Purpose — In Context (Level A)

The purpose of each link can be determined from the link text alone or from the link text together with its programmatically determined link context, except where the purpose of the link would be ambiguous to users in general.
View 2.4.4 on W3C ↗

2.4.5 Multiple Ways (Level AA)

More than one way is available to locate a Web page within a set of Web pages except where the Web Page is the result of, or a step in, a process.
View 2.4.5 on W3C ↗

2.4.6 Headings and Labels (Level AA)

Headings and labels describe topic or purpose.
View 2.4.6 on W3C ↗

2.4.7 Focus Visible (Level AA)

Any keyboard operable user interface has a mode of operation where the keyboard focus indicator is visible.
View 2.4.7 on W3C ↗

2.4.11 Focus Not Obscured (Minimum) (Level AA) NEW 2.2

When a user interface component receives keyboard focus, the component is not entirely hidden due to author-created content.
View 2.4.11 on W3C ↗
2.5Input ModalitiesModerateExample6 criteria

Support various input methods beyond keyboard — touch, pointer, voice, motion.

A2.5.1 Pointer Gestures
A2.5.2 Pointer Cancellation
A2.5.3 Label in Name
A2.5.4 Motion Actuation
AA2.5.7 Dragging Movements2.2
AA2.5.8 Target Size (Minimum)2.2

Common failures:

  • Pinch-to-zoom as the only way to enlarge a map — no tap/button alternative
  • Tiny close buttons (12x12px) on modals and popups
  • Drag-and-drop reordering with no arrow-key or select-based alternative
Insufficient Target Size — SC 2.5.8
×16x16px close button — too small
<button style="width: 16px;
  height: 16px; padding: 0">
  &times;
</button>
24x24px minimum met
<button style="min-width: 24px;
  min-height: 24px; padding: 4px"
  aria-label="Close dialog">
  &times;
</button>
W3C 2.2 Normative Text

2.5.1 Pointer Gestures (Level A)

All functionality that uses multipoint or path-based gestures for operation can be operated with a single pointer without a path-based gesture, unless a multipoint or path-based gesture is essential.
View 2.5.1 on W3C ↗

2.5.2 Pointer Cancellation (Level A)

For functionality that can be operated using a single pointer, at least one of the following is true: No Down-Event (the down-event of the pointer is not used to execute any part of the function), Abort or Undo (completion of the function is on the up-event, and a mechanism is available to abort the function before completion or to undo the function after completion), Up Reversal (the up-event reverses any outcome of the preceding down-event), Essential (completing the function on the down-event is essential).
View 2.5.2 on W3C ↗

2.5.3 Label in Name (Level A)

For user interface components with labels that include text or images of text, the name contains the text that is presented visually.
View 2.5.3 on W3C ↗

2.5.4 Motion Actuation (Level A)

Functionality that can be operated by device motion or user motion can also be operated by user interface components and responding to the motion can be disabled to prevent accidental actuation, except when the motion is used to operate functionality through an accessibility supported interface or the motion is essential for the function.
View 2.5.4 on W3C ↗

2.5.7 Dragging Movements (Level AA) NEW 2.2

All functionality that uses a dragging movement for operation can be achieved by a single pointer without dragging, unless dragging is essential or the functionality is determined by the user agent and not modified by the author.
View 2.5.7 on W3C ↗

2.5.8 Target Size — Minimum (Level AA) NEW 2.2

The size of the target for pointer inputs is at least 24 by 24 CSS pixels, except where: Spacing (undersized targets have sufficient spacing), Equivalent (the function can be achieved through a different control on the same page that meets this criterion), Inline (the target is in a sentence or its size is otherwise constrained by the line-height of non-target text), User Agent Control (the size of the target is determined by the user agent and is not modified by the author), Essential (a particular presentation of the target is essential or is legally required for the information being conveyed).
View 2.5.8 on W3C ↗
U

Principle 3: Understandable

Information and UI operation must be understandable — 13 criteria

3.1ReadableHighExample2 criteria

Make text content readable and understandable. The language must be programmatically determinable so screen readers use the correct pronunciation engine. Missing lang is the #2 most common WCAG failure (WebAIM Million 2025).

A3.1.1 Language of Page
AA3.1.2 Language of Parts

Common failures:

  • Missing lang attribute on <html> element — found on 17.1% of pages (WebAIM Million 2025)
  • Incorrect language code (e.g. lang="english" instead of lang="en")
  • Spanish content sections without lang="es"
Missing Language Declaration — SC 3.1.1
×No lang attribute — screen reader guesses
<html>
  <head>
    <title>Water District</title>
  </head>
Language declared — correct pronunciation
<html lang="en">
  <head>
    <title>Water District</title>
  </head>
W3C 2.2 Normative Text

3.1.1 Language of Page (Level A)

The default human language of each Web page can be programmatically determined.
View 3.1.1 on W3C ↗

3.1.2 Language of Parts (Level AA)

The human language of each passage or phrase in the content can be programmatically determined except for proper names, technical terms, words of indeterminate language, and words or phrases that have become part of the vernacular of the immediately surrounding text.
View 3.1.2 on W3C ↗
3.2PredictableModerateExample5 criteria

Pages appear and operate in predictable ways — consistent navigation and identification.

A3.2.1 On Focus
A3.2.2 On Input
AA3.2.3 Consistent Navigation
AA3.2.4 Consistent Identification
A3.2.6 Consistent Help2.2

Common failures:

  • Selecting a country in a dropdown auto-navigates to a different page
  • Navigation items appear in different order on different pages
  • Search icon labeled "Search" on one page and "Find" on another
Auto Context Change — SC 3.2.2
×Selecting navigates away — no warning
<select
  onchange="location=this.value">
  <option>Select district</option>
  <option value="/north">North</option>
  <option value="/south">South</option>
</select>
Explicit submit button required
<select id="district">
  <option>Select district</option>
  <option value="/north">North</option>
  <option value="/south">South</option>
</select>
<button type="submit">Go</button>
W3C 2.2 Normative Text

3.2.1 On Focus (Level A)

When any user interface component receives focus, it does not initiate a change of context.
View 3.2.1 on W3C ↗

3.2.2 On Input (Level A)

Changing the setting of any user interface component does not automatically cause a change of context unless the user has been advised of the behavior before using the component.
View 3.2.2 on W3C ↗

3.2.3 Consistent Navigation (Level AA)

Navigational mechanisms that are repeated on multiple Web pages within a set of Web pages occur in the same relative order each time they are repeated, unless a change is initiated by the user.
View 3.2.3 on W3C ↗

3.2.4 Consistent Identification (Level AA)

Components that have the same functionality within a set of Web pages are identified consistently.
View 3.2.4 on W3C ↗

3.2.6 Consistent Help (Level A) NEW 2.2

If a Web page contains any of the following help mechanisms, and those mechanisms are repeated on multiple Web pages within a set of Web pages, they occur in the same order relative to other page content, unless a change is initiated by the user: human contact details, human contact mechanism, self-help option, a fully automated contact mechanism.
View 3.2.6 on W3C ↗
3.3Input AssistanceCriticalExample6 criteria

Help users avoid and correct mistakes — labels, error messages, and confirmation steps.

A3.3.1 Error Identification
A3.3.2 Labels or Instructions
AA3.3.3 Error Suggestion
AA3.3.4 Error Prevention
A3.3.7 Redundant Entry2.2
AA3.3.8 Accessible Authentication2.2

Common failures:

  • Form fields with only placeholder text and no visible label
  • Validation errors shown only by turning the field border red
  • Login forms that block password managers or prevent pasting
Missing Form Label — SC 3.3.2
×Placeholder is not a label
<input type="email"
       placeholder="Email">
Explicit label association
<label for="email">Email</label>
<input type="email" id="email"
       placeholder="you@example.com">
Rendered Preview

No programmatic label — screen reader says "edit text, blank"

Screen reader says "Email, edit text"

W3C 2.2 Normative Text

3.3.1 Error Identification (Level A)

If an input error is automatically detected, the item that is in error is identified and the error is described to the user in text.
View 3.3.1 on W3C ↗

3.3.2 Labels or Instructions (Level A)

Labels or instructions are provided when content requires user input.
View 3.3.2 on W3C ↗

3.3.3 Error Suggestion (Level AA)

If an input error is automatically detected and suggestions for correction are known, then the suggestions are provided to the user, unless it would jeopardize the security or purpose of the content.
View 3.3.3 on W3C ↗

3.3.4 Error Prevention — Legal, Financial, Data (Level AA)

For Web pages that cause legal commitments or financial transactions for the user to occur, that modify or delete user-controllable data in data storage systems, or that submit user test responses, at least one of the following is true: Reversible (submissions are reversible), Checked (data entered by the user is checked for input errors and the user is provided an opportunity to correct them), Confirmed (a mechanism is available for reviewing, confirming, and correcting information before finalizing the submission).
View 3.3.4 on W3C ↗

3.3.7 Redundant Entry (Level A) NEW 2.2

Information previously entered by or provided to the user that is required to be entered again in the same process is either auto-populated, or available for the user to select. Except when re-entering the information is essential, or the information is required to ensure the security of the content, or previously entered information is no longer valid.
View 3.3.7 on W3C ↗

3.3.8 Accessible Authentication — Minimum (Level AA) NEW 2.2

A cognitive function test (such as remembering a password or solving a puzzle) is not required for any step in an authentication process unless that step provides at least one of the following: Alternative (another authentication method that does not rely on a cognitive function test), Mechanism (a mechanism is available to assist the user in completing the cognitive function test), Object Recognition (the cognitive function test is to recognize objects), Personal Content (the cognitive function test is to identify non-text content the user provided to the Web site).
View 3.3.8 on W3C ↗
R

Principle 4: Robust

Content must work reliably with assistive technologies — 2 criteria

4.1CompatibleCriticalExample2 criteria

Maximize compatibility with current and future user agents, including assistive technologies.

A4.1.2 Name, Role, Value
AA4.1.3 Status Messages

4.1.1 Parsing — retired in WCAG 2.2. Originally required well-formed markup, but modern browsers and assistive technologies handle parsing errors gracefully. This criterion is always met in current HTML.

Common failures:

  • Custom components (tabs, accordions, modals) built with divs and no ARIA roles
  • Toggle buttons missing aria-pressed state
  • Toast notifications that appear without role="status"
Missing ARIA Role — SC 4.1.2
×Custom tab with no role or state
<div class="tab"
     onclick="switchTab(1)">
  Account Info
</div>
ARIA tab role with state
<button role="tab"
        aria-selected="true"
        aria-controls="panel-1">
  Account Info
</button>
Rendered Preview
Account Info

Screen reader: "Account Info" — no indication it's a tab or if selected

Account Info

Screen reader: "Account Info, tab, selected, 1 of 3"

W3C 2.2 Normative Text

4.1.2 Name, Role, Value (Level A)

For all user interface components (including but not limited to: form elements, links and components generated by scripts), the name and role can be programmatically determined; states, properties, and values that can be set by the user can be programmatically set; and notification of changes to these items is available to user agents, including assistive technologies.
View 4.1.2 on W3C ↗

4.1.3 Status Messages (Level AA)

In content implemented using markup languages, status messages can be programmatically determined through role or properties such that they can be presented to the user by assistive technologies without receiving focus.
View 4.1.3 on W3C ↗
C

Section 5: Conformance

Rules that define what it means to "conform" to WCAG — 5 requirements

5.1Conformance Levels: A, AA, AAA3 levels

WCAG defines three conformance levels. Each level includes all criteria from the level(s) below it. A site claiming Level AA must satisfy every Level A and every Level AA success criterion.

Level AMinimum — Essential Accessibility

The bare minimum. Level A criteria address barriers that completely prevent certain users from accessing content — e.g., no alt text on images, no keyboard access, flashing content that causes seizures. Without Level A, entire user groups are locked out.

Implication: Failing Level A means fundamental barriers exist. No court or regulator considers a site accessible if Level A criteria are unmet. These are the “blocking” issues.

Level AAStandard — The Legal Benchmark

Level AA is the universally accepted target. It adds criteria that make content genuinely usable — sufficient color contrast (4.5:1), captions on live video, consistent navigation, visible focus indicators, and error suggestions on forms. This is the level referenced by the DOJ's 2024 Title II rule, the EU's EN 301 549, and virtually every ADA settlement agreement.

Implication: Level AA is the de facto legal standard worldwide. When a lawsuit or settlement says “WCAG 2.2 conformance,” they mean Level AA. This is the level every section of this page targets.

Level AAAEnhanced — Highest Accessibility

The most stringent level. Level AAA adds criteria like 7:1 contrast ratios, sign language interpretation for all video, no time limits whatsoever, and reading-level accommodations. W3C itself states that “it is not recommended that Level AAA conformance be required as a general policy for entire sites because it is not possible to satisfy all Level AAA success criteria for some content.”

Implication: No law or regulation requires full AAA conformance. However, individual AAA criteria can still be valuable goals — particularly for content targeting audiences with cognitive or learning disabilities.

How levels build on each other: WCAG 2.2 Level AA includes 55 success criteria — 32 at Level A plus 23 at Level AA. Level AAA adds another 23 criteria on top. Conformance is cumulative: you cannot claim AA while skipping any A criterion.

5.2Conformance Requirements5 requirements

These are not testable success criteria — they define the rules for claiming conformance. Failing any one means the page does not conform.

Req5.2.1 Conformance Level
Req5.2.2 Full Pages
Req5.2.3 Complete Processes
Req5.2.4 Accessibility-Supported
Req5.2.5 Non-Interference

Key implications:

  • No partial credit — one failure on a page means the page does not conform
  • Process-wide — a conforming homepage means nothing if the bill-pay flow is broken
  • Third-party content — embedded widgets, iframes, and ads count unless you claim partial conformance under 5.4
  • Non-interference — a broken overlay or auto-playing video can invalidate an otherwise conforming page
5.3–5.5Claims & Partial Conformance3 sections
Ref5.3 Conformance Claims (Optional)
Ref5.4 Partial Conformance — Third Party
Ref5.5 Partial Conformance — Language

Practical notes:

  • Conformance claims are optional — courts care about actual accessibility, not self-declarations
  • The third-party exception is narrow — if you chose to embed it, you're responsible for vetting it
  • Publishing an accessibility statement (even without a formal claim) is a strong good-faith signal