ADA Title III website accessibility lawsuits hit over 4,500 in 2023 alone. The European Accessibility Act (EAA) is now in its enforcement ramp-up. Google includes accessibility metrics in Core Web Vitals. And WCAG 2.2 introduced new success criteria that changed what "compliant" means.
This checklist covers exactly what your website needs to be compliant with WCAG 2.2 AA in 2026 — plus the legal landscape, deadlines, and how to prioritize fixes.
Understanding the Legal Landscape in 2026
Three legal frameworks drive website accessibility requirements. Which ones apply to you depends on where your business operates and who your customers are.
1. ADA Title III (United States)
The Americans with Disabilities Act Title III requires "places of public accommodation" to be accessible. Courts have consistently ruled that websites fall under this requirement. While the DOJ hasn't issued specific technical standards for websites, courts have adopted WCAG 2.0 AA and increasingly WCAG 2.1 AA as the de facto standard. With WCAG 2.2 now published, expect the benchmark to shift.
2. European Accessibility Act (EU)
The EAA takes full effect June 28, 2025. It requires most digital products and services sold in the EU to meet EN 301 549 (which references WCAG 2.1 AA). Unlike the ADA, the EAA has clear enforcement mechanisms and penalties. If you sell to EU customers, this is mandatory — not a risk-management question.
3. Section 508 (US Federal)
If you sell software or services to the US federal government, Section 508 requires WCAG 2.0 AA compliance (being updated to WCAG 2.1). This affects government contractors and any business that wants to win government contracts.
The Complete WCAG 2.2 AA Compliance Checklist
Work through these items in order. Each builds on the previous one. Don't skip to the technical fixes until you have a baseline.
Phase 1: Assessment (Week 1)
Run an automated scan on your top 5 pages
Use a free tool or paid audit to establish your baseline. Capture the score, number of critical issues, and the most common failure types. This is your starting point.
Document your current accessibility score
Record your baseline score so you can measure progress. Most automated tools give a 0-100 score. Anything below 60 needs urgent attention.
Identify your highest-traffic user flows
List the 3-5 most common tasks users perform on your site: signup, checkout, account management, search, contact form. These should be your first remediation targets.
Phase 2: Quick Wins (Week 1-2)
These fixes address 80% of automated scan failures and can often be done in a single development sprint.
Fix color contrast failures
WCAG 2.2 AA requires a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text (18px+ bold or 24px+ regular). This is the single most common failure — our scans show 94% of sites have at least one contrast violation.
Add alt text to all images
Every <img> element needs an alt attribute. Decorative images should use alt="" (empty). Informational images need descriptive alternative text. This affects screen reader users and image search ranking.
Fix heading hierarchy
Your page should have exactly one h1 and headings should nest properly (h1 → h2 → h3, never skip levels). This helps screen reader users navigate and improves SEO.
Add labels to all form fields
Every <input>, <select>, and <textarea> needs an associated <label>. Placeholder text is not a substitute — it disappears on focus and fails WCAG.
Fix link purpose and text
Links like "click here" and "read more" fail WCAG 2.2. Every link should describe its destination. If you have multiple links to different pages with the same text, a screen reader user can't distinguish them.
Ensure touch targets are at least 24×24px
WCAG 2.2 introduced (and WCAG 2.2 AA adopted) a minimum touch target size of 24×24 CSS pixels for interactive elements on mobile. Small buttons and closely packed links are the most common failures.
Phase 3: Structural Fixes (Week 2-3)
Implement skip navigation links
A "Skip to content" link at the top of every page lets keyboard users bypass repeated navigation. This is a WCAG 2.0 requirement and one of the easiest fixes.
Fix ARIA landmark regions
Use ARIA landmarks (banner, navigation, main, contentinfo) to define page regions. This helps screen reader users jump between sections without tabbing through everything.
Ensure focus indicators are visible
Remove outline: none from your CSS or replace it with a custom focus style. Keyboard users need to see where focus is at all times. WCAG 2.2 requires a minimum 2px focus indicator with 3:1 contrast against the background.
Fix tab order and keyboard traps
Tab through every interactive element on your site. The order should follow the visual layout (left to right, top to bottom). Ensure no element traps keyboard focus (a common issue with modals and custom widgets).
Phase 4: Validation (Week 3-4)
Run a second automated scan
After fixing the quick wins, re-scan to verify your fixes actually resolved the issues. Your score should have improved significantly (30+ points if you had critical issues).
Test with screen readers
Test your key user flows with NVDA (Windows, free) and VoiceOver (Mac, built-in). Can you complete checkout without a mouse? Do form errors get announced? Can you navigate the entire site with Tab and arrow keys?
Test with keyboard only
Unplug your mouse. Can you navigate every page, open every menu, submit every form, and dismiss every modal using only the keyboard? If not, those elements fail WCAG.
Generate compliance documentation
Produce an accessibility report with your scan results, fixes applied, and remaining issues. This is your evidence of good faith compliance efforts — critical if you're ever challenged legally.
Need a Compliance Report You Can Act On?
Our automated WCAG 2.2 AA audit scans your site and delivers a styled PDF report with every issue mapped to the exact page element, severity rating, and fix recommendation. Start with a single URL and see what you're dealing with.
Get Your Audit — $249 →What WCAG 2.2 Changed (New Success Criteria)
WCAG 2.2 introduced several new success criteria that didn't exist in WCAG 2.1. If your last audit was done against an older standard, you may have gaps:
- 2.4.11 Focus Not Obscured (AA): When a component receives keyboard focus, it must not be hidden behind other content. Common in sticky headers and cookie banners.
- 2.4.12 Focus Not Obscured (AAA): Stricter version — no part of the focused element may be hidden.
- 2.4.13 Focus Appearance (AAA): Focus indicator must be at least as large as a 2px border perimeter and have 3:1 contrast against adjacent colors.
- 2.5.7 Dragging Movements (AA): If an operation requires dragging, there must be an alternative single-pointer interaction (like a click-to-select alternative).
- 2.5.8 Target Size (AA): Interactive targets must be at least 24×24 CSS pixels (with some exceptions). This affects mobile navigation and small buttons.
- 3.2.6 Consistent Help (A): If you provide help mechanisms (chat, phone, email, contact form), they must be in the same relative order across pages.
- 3.3.7 Accessible Authentication (A): If a login process requires cognitive function tests (CAPTCHAs, puzzles, memorized passwords), there must be an alternative that doesn't rely on cognitive ability.
- 3.3.8 Accessible Authentication (AAA): Stricter version — no cognitive function tests at all (though object recognition and simple character matching are OK).
Common Pitfalls That Automated Tools Won't Catch
An automated scan catches about 70% of WCAG issues. The remaining 30% require human judgment. Here's what an automated scan misses:
- Logical reading order: Does the content make sense when read linearly (as a screen reader would)? Automated tools can't judge narrative flow.
- Screen reader announcement quality: Is dynamic content announced properly? Do ARIA live regions fire at the right time? These require manual testing.
- Keyboard navigation flow: Does tab order match the visual layout? Are all interactive elements reachable by keyboard? A tool can detect missing tabindex but not a confusing navigation flow.
- Context-dependent accessibility: Is a color-only instruction ("click the green button") still accessible to someone who can't distinguish colors? Tools can detect low contrast but not meaning conveyed through color alone.
- Error identification: When a form submission fails, does a screen reader user know which field has the error and why? This requires testing with actual assistive technology.
This is why a full compliance program includes both automated scanning and manual testing. Start with automation — it's fast, cheap, and catches the low-hanging fruit. Then validate with human testing on the critical user flows.
Prioritization Matrix: What to Fix First
Not all accessibility issues are equal. Here's how to prioritize your fixes:
- Critical (fix immediately): Keyboard traps, missing form labels, missing alt text on information-carrying images, focus indicators stripped by CSS. These block users entirely.
- High (fix this sprint): Color contrast failures, heading hierarchy issues, empty links/buttons, missing ARIA landmarks. These cause significant difficulty but don't block users entirely.
- Medium (fix next sprint): Touch target size, focus order issues, redundant title attributes, missing skip links. These degrade the experience but have workarounds.
- Low (fix when convenient): Best practice recommendations, AAA-level criteria, decorative improvements. These polish the experience but aren't barriers.
Cost of Compliance vs Cost of Non-Compliance
Let's look at the numbers:
- Automated audit + fixes: $249–$2,000 (one-time)
- Full manual audit + remediation: $5,000–$25,000
- ADA Title III lawsuit settlement (out of court): $15,000–$50,000+
- ADA Title III lawsuit (trial verdict): $50,000–$100,000+ plus legal fees
- EAA non-compliance fines (EU): Up to 2% of annual revenue in some member states
The cheapest option is clear. Most businesses that run an automated audit find that 80% of their critical issues can be fixed in a single development sprint, and the audit pays for itself in reduced legal risk alone.
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