WCAG 2.2 AA: How It Impacts Your Website's ADA Compliance

If you're managing a website or planning a redesign, you've probably heard about WCAG 2.2—the latest version of the Web Content Accessibility Guidelines that became official in October 2023. But here's what matters for your website: WCAG 2.2 added nine new success criteria, and six of them are now requirements for standard AA compliance.

Whether you're a Texas state agency facing accessibility requirements under HB 5195, a higher education institution, or a business that wants to create inclusive digital experiences (and avoid lawsuits), understanding these updates is essential. Let's break down what's changed and what it means for your website.

Why WCAG 2.2 Matters Now

First, a quick reality check: 98.1% of homepages have detectable accessibility issues. And the legal risks are accelerating fast—over 4,000 digital accessibility lawsuits were filed in 2024, with 2025 on track to surge nearly 20% higher.

WCAG 2.2 isn't just about avoiding lawsuits, though. It's about creating better experiences for everyone. The new criteria focus heavily on mobile accessibility, authentication challenges, and helping people with cognitive disabilities—areas where websites have historically struggled.

If your website was built to meet WCAG 2.1 AA standards, you're not starting from scratch. But you do need to address six new requirements to maintain compliance.

WCAG 2.2 Updates That Impact Your Website

These are the success criteria you need to address for standard AA or A compliance. If you're redesigning your website or auditing for accessibility, these are your priorities.

Here's something important to know: Half of these new requirements—Focus Not Obscured, Dragging Movements, and Target Size—are directly driven by mobile usage patterns. As mobile traffic continues to dominate (over 60% of web traffic now comes from mobile devices), WCAG 2.2 reflects the reality that accessibility on small screens with touch interfaces is just as critical as desktop keyboard navigation.

1. Focus Not Obscured (Minimum) – Level AA

What it means: When someone navigates your site with a keyboard (like people who can't use a mouse), the item with focus can't be completely hidden by other content—like sticky headers, cookie banners, or chat widgets.

Why it matters: Imagine trying to fill out a form, but you can't see which field you're in because your "sticky footer" is covering it. That's the problem this solves.

Real-world example: You know those "Subscribe to our newsletter!" banners that stick to the bottom of every page? If they hide the focused form field when someone tabs through your contact form, you're not compliant.

The fix: Make sure your sticky elements don't completely obscure focused items. At minimum, part of the focused element needs to be visible.

2. Dragging Movements – Level AA

What it means: Any functionality that requires dragging (like reordering items in a list, using a slider, or moving cards) must have an alternative method that doesn't require dragging.

Why it matters: People with hand tremors, motor disabilities, or those using assistive technologies can't accurately drag items. They need another way.

Real-world example: If you have a "Build Your Own Product" configurator that requires dragging ingredients or components into a builder, you need to provide buttons (like up/down arrows or add/remove options) as alternatives.

The fix: Add buttons, dropdowns, or other single-click alternatives for any drag-based interactions.

3. Target Size (Minimum) – Level AA

What it means: Clickable targets (buttons, links, icons) need to be at least 24 by 24 CSS pixels, OR have enough spacing around them so they don't overlap with other targets.

Why it matters: Small, tightly packed buttons are hard to tap on mobile devices and difficult for people with motor disabilities or hand tremors.

Real-world example: Those tiny social media icons crammed together in your footer? If they're smaller than 24x24 pixels and touching each other, they're not compliant. Links in body text get an exception, but navigation items and buttons don't.

The fix: Make your buttons bigger (at least 24x24 pixels) or space them out so there's adequate room between targets.

4. Accessible Authentication (Minimum) – Level AA

What it means: You can't require users to remember passwords, solve puzzles, or retype one-time codes to log in—unless you provide an alternative like password managers, email magic links, or biometric authentication.

Why it matters: People with cognitive disabilities struggle with traditional authentication. Forcing them to remember complex passwords or solve CAPTCHAs creates unnecessary barriers.

Real-world example: If your member portal requires users to type their username and password from memory with no support for password managers or "magic link" email login, you're not compliant.

The fix: Support password managers (don't block paste functionality), offer passwordless authentication options (like email magic links), or provide biometric login on supported devices.

5. Consistent Help – Level A

What it means: If you offer help mechanisms (live chat, contact forms, phone numbers, FAQs) on multiple pages, they need to appear in the same relative location on each page.

Why it matters: People with cognitive disabilities may struggle to find help if its location keeps changing. Consistency reduces cognitive load.

Real-world example: If your "Contact Us" link appears in the top-right navigation on your homepage but in the footer on product pages, that's inconsistent placement.

The fix: Put your help mechanisms in the same spot across all pages. If you have a chat widget, keep it in the same corner on every page.

6. Redundant Entry – Level A

What it means: Don't make users re-enter information they've already provided in the same session (like multi-step forms or checkout processes).

Why it matters: Re-entering information is frustrating for everyone, but especially challenging for people with cognitive disabilities or memory issues.

Real-world example: If users enter their shipping address on Step 2 and you ask them to re-enter it as their billing address on Step 4 (instead of offering a "same as shipping" option or auto-populating), that's redundant entry.

The fix: Auto-populate information users have already provided, or give them a checkbox to reuse previous entries.

WCAG 2.2 Updates That Don't Impact Most Websites

These three new success criteria are Level AAA, which is considered "enhanced" accessibility. They're great goals, but they're not required for standard compliance. Most organizations focus on meeting Level AA.

7. Focus Not Obscured (Enhanced) – Level AAA

This is the stricter version of #1 above. Instead of just requiring that focused elements be partially visible, this requires they be fully visible—no part can be hidden by sticky headers, footers, or other content.

Why most sites don't need to worry: Level AA only requires partial visibility, which is the standard compliance level.

8. Focus Appearance – Level AAA

This requires that the focus indicator (the outline showing where keyboard focus is) meet specific size and contrast requirements: at least 2 CSS pixels thick and with a 3:1 contrast ratio.

Why most sites don't need to worry: While good focus indicators are best practice, this specific requirement is AAA-level, not required for standard compliance. (However, you still need some visible focus indicator for Level A compliance under older criteria.)

9. Accessible Authentication (Enhanced) – Level AAA

This is the stricter version of #4 above. It prohibits requiring users to recognize objects (like "click all the images with cars") or identify content they previously uploaded, even as alternatives to cognitive function tests.

Why most sites don't need to worry: Level AA already requires accessible authentication alternatives. This just sets a higher bar that most organizations don't need to meet.

One More Important Change: 4.1.1 Parsing is Gone

WCAG 2.2 also removed one old success criterion: 4.1.1 Parsing (which required valid HTML code). This doesn't mean you should write bad code—it just means modern browsers and assistive technologies are better at handling imperfect HTML, so it's no longer a formal requirement.

What This Means for Your Website Redesign

If you're planning a website redesign or refresh, now's the perfect time to build in these WCAG 2.2 requirements from the start. Here's what that looks like:

Design Phase:

• Plan for 24x24 pixel minimum touch targets (or proper spacing)
• Design visible focus indicators that don't get hidden by sticky elements
• Include non-drag alternatives in any interactive features

Development Phase:

• Implement accessible authentication (support password managers, consider magic links)
• Ensure help mechanisms appear consistently across pages
• Auto-populate form data to avoid redundant entry

Content Phase:

• Audit existing multi-step processes for redundant data entry
• Review login flows for cognitive accessibility

A Note About WordPress and Other CMS Platforms

If your website runs on WordPress or another CMS, you might be wondering: "Won't my theme or plugins handle this automatically?"

The short answer: maybe, but probably not completely.

While some WordPress themes and plugins include accessibility features, many don't—and even those that do often fall short on these new WCAG 2.2 requirements. Pre-built themes prioritize visual design over accessibility, and third-party plugins can introduce compliance issues that are difficult to fix without customization.

Custom-built websites give you much better control over WCAG 2.2 compliance from the start. When accessibility is baked into your design system and codebase—rather than bolted on through plugins—you get better performance, easier maintenance, and confidence that your site actually meets the standards. Plus, you won't be at the mercy of a theme developer who may or may not update their code when accessibility requirements change.

The Texas Connection

If you're a Texas state agency, WCAG 2.2 compliance isn't optional—it's part of the HB 5195 requirements that took effect September 1, 2025. Your November 2026 status report to the legislature needs to show meaningful progress on digital accessibility, and that includes meeting current WCAG standards.

But even if you're not a state agency, the trend is clear: accessibility compliance is becoming table stakes for digital services across the board. Courts are increasingly ruling that websites are "places of public accommodation" under the ADA, which means accessibility isn't just good practice—it's a legal requirement.

How Monkee-Boy Can Help

At Monkee-Boy, we've been building accessible websites for Texas organizations for years. We don't just check boxes—we create digital experiences that work beautifully for everyone.

Here's how we approach WCAG 2.2 compliance:

Accessibility Audits: We'll review your current website against WCAG 2.2 AA standards and give you a prioritized roadmap of what needs to be fixed.

Accessible Redesigns: If you're planning a website refresh, we build accessibility in from the ground up—it's typically easier (and cheaper) than retrofitting accessibility to an existing site.

Remediation Services: Already have a site that needs updates? Once an up-front audit is completed, our team can help you determine if a redesign is needed or if we can remediate accessibility issues on your current sites without requiring a full redesign.

Ongoing Compliance: Accessibility isn't one-and-done. It's a journey, not a destination. As such, we provide ongoing monitoring and support to keep your site compliant as standards evolve and your content grows.

We understand that accessibility can feel overwhelming—especially when you're trying to keep up with changing requirements while also serving your users and growing your organization. That's where we come in. We'll guide you through the digital jungle, prioritize what matters most, and create a plan that fits your timeline and budget.

The Bottom Line

Whether you're facing Texas HB 5195 deadlines, planning a website redesign, or just want to create more inclusive digital experiences, now's the time to address WCAG 2.2 compliance. You don't have to be an expert or navigate this journey alone. A qualified agency, like Monkee-Boy, can hold your hand through the entire process.