Is WCAG 2.2 required?
A straight, vendor-neutral answer: what the law actually mandates, and why targeting 2.2 is still the right call.
Where each rule stands
| Who / where | Standard required | WCAG 2.2 required? |
|---|---|---|
| U.S. state & local government (ADA Title II) | WCAG 2.1 AA | No |
| U.S. federal agencies (Section 508) | WCAG 2.0 AA | No |
| U.S. private business (ADA Title III) | No named standard | No |
| EU consumer products & services (EAA) | EN 301 549 (WCAG 2.1 AA baseline) | Not yet; the standard is moving toward 2.2 |
The detail and sources for each row are on two pages: ADA Title II and the version question, and the full standards landscape (Section 508, the EU, and state laws).
Why target 2.2 anyway
An honest case for building to WCAG 2.2 AA today, even though no U.S. law requires it:
- It costs almost nothing extra. WCAG 2.2 is backward-compatible, so meeting it automatically satisfies the WCAG 2.1 AA the law requires. There is no trade-off (Source: W3C WAI, WCAG 2 overview ) .
- It future-proofs. Because there are no breaking changes, building to 2.2 now means no remediation scramble when the required line moves up, which it has historically done.
- Auditors increasingly test against it. The new criteria close real gaps a 2.1 checklist misses, and accessibility auditors increasingly evaluate to 2.2. (The U.S. litigation benchmark remains 2.1 AA; testing to 2.2 is prudence, not a legal mandate.)
- EU exposure. Any organization serving EU consumers is in scope for the European Accessibility Act, and the EU’s harmonized standard is moving to WCAG 2.2.
- It maps to real harm. The new criteria target documented barriers, including CAPTCHA and authentication, small touch targets, drag-only interactions, and focus visibility.
Should you wait for WCAG 3.0?
No. WCAG 3.0 is an early-stage W3C Working Draft, not a finished standard, and is years from completion. W3C itself says it is “inappropriate to cite this document as other than a work in progress” (Source: W3C, WCAG 3.0 Working Draft ) . It will not change current obligations for years, and it will coexist with WCAG 2.x rather than replacing it overnight. WCAG 2.2 is the current, stable standard to build to.
A note on legal advice
Common questions
Is WCAG 2.2 legally required in the United States?
No. No U.S. federal law currently requires WCAG 2.2. The ADA Title II rule for state and local government requires WCAG 2.1 AA; Section 508 for federal agencies requires WCAG 2.0 AA; and ADA Title III for private business names no specific version at all.
Does the ADA require WCAG 2.2?
No. The 2024 ADA Title II rule adopts WCAG 2.1 Level AA, not 2.2. Title III, which covers private businesses, has no regulation specifying any WCAG version.
Should I target WCAG 2.1 or 2.2?
For new work, target 2.2 AA. Because 2.2 is backward-compatible, meeting it also satisfies the 2.1 AA the law requires, at essentially no extra cost, and it future-proofs against coming updates.