Resource guide

The EAA and WCAG 2.2

The EAA sets the legal requirement. WCAG 2.2 provides the technical standard to meet it. Here is how they fit together.

By Calling All Minds·Last updated April 2026

87

Success criteria

Across all three conformance levels.

AA

Legal compliance target

Presumption of conformity with the EAA.

9

New in WCAG 2.2

Added since version 2.1.

POUR

Four principles

Perceivable, Operable, Understandable, Robust.

EAA & WCAG 2.2

The law and the standard

The European Accessibility Act tells you what you must achieve: accessible products and services. But it does not provide a detailed technical checklist. Instead, it points to a European harmonised standard called EN 301 549 — Accessibility requirements for ICT products and services.

EN 301 549 is the bridge. It takes the EAA's legal requirements and maps them to specific, testable technical criteria. For web content, those criteria come directly from the Web Content Accessibility Guidelines (WCAG) 2.2, published by the World Wide Web Consortium (W3C).

In practical terms: if your website meets WCAG 2.2 Level AA, you benefit from a presumption of conformity with the EAA's digital accessibility requirements. Regulators will presume you are compliant unless evidence shows otherwise.

The chain of compliance

EAA (the law) → EN 301 549 (the European standard) → WCAG 2.2 (the technical criteria). Meet WCAG 2.2 AA, and you are presumed to comply with the EAA for your digital content.

How this maps to UK law

The UK's Public Sector Bodies Accessibility Regulations 2018 reference WCAG 2.1 AA through EN 301 549. The Equality Act 2010 does not reference a specific technical standard, but courts and regulators increasingly look to WCAG as the benchmark for what constitutes a reasonable adjustment. Meeting WCAG 2.2 AA puts you in a strong position under both UK and EU frameworks.

EAA & WCAG 2.2

What is WCAG 2.2?

WCAG stands for Web Content Accessibility Guidelines. Published by the W3C's Accessibility Guidelines Working Group, it is the globally recognised standard for making web content accessible. Version 2.2 was published on 5 October 2023 and is the current recommended standard.

WCAG 2.2 contains 87 success criteria — specific, testable requirements that your content either passes or fails. These are organised under four foundational principles known as POUR:

P

Perceivable

Information must be presentable in ways all users can perceive.

O

Operable

Interface components must be usable by everyone.

U

Understandable

Information and UI operation must be comprehensible.

R

Robust

Content must work reliably with current and future technologies.

EAA & WCAG 2.2

Conformance levels: A, AA, and AAA

Each of the 87 success criteria is assigned one of three conformance levels. The levels are cumulative — meeting Level AA means you also meet Level A.

A32 criteria

Essential baseline

The minimum level. Without these, some users will find it impossible to use your content at all. Think of this as removing the most severe barriers.

AA24 additional criteria (56 total)

The legal standard

This is what most accessibility laws, including the EAA, require. It addresses the most common barriers for the widest range of users. This is your compliance target.

AAA31 additional criteria (87 total)

Enhanced accessibility

The highest standard. Not all AAA criteria are achievable for all content types, but striving toward them creates genuinely inclusive experiences. This is where you go beyond compliance to true inclusion.

EAA & WCAG 2.2

Why this guide covers AAA too

Most guides stop at Level AA because that is what the law requires. We go further for two reasons.

First, the law is a floor, not a ceiling. Meeting AA makes you legally compliant, but many people — particularly those with cognitive disabilities, learning differences, or low vision — benefit enormously from AAA criteria. At Calling All Minds, we believe in going beyond minimum compliance to create experiences that genuinely work for everyone.

Second, standards move forward. What is AAA today may become AA in a future version. WCAG 3.0 is already in development. Organisations that understand and work toward AAA are better positioned for whatever comes next.

EAA & WCAG 2.2

What is new in WCAG 2.2?

WCAG 2.2 builds on version 2.1 by adding nine new success criteria. One criterion from 2.1 (4.1.1 Parsing) was also removed as obsolete, since modern browsers now handle HTML parsing errors gracefully.

The new criteria focus on three areas where 2.1 had gaps: cognitive accessibility, mobile usability, and improved keyboard navigation.

2.4.11
Focus Not Obscured (Minimum)AA

Keyboard focus must not be completely hidden by other content.

2.4.12
Focus Not Obscured (Enhanced)AAA

Keyboard focus must be fully visible.

2.4.13
Focus AppearanceAAA

Focus indicators must be sufficiently visible.

2.5.7
Dragging MovementsAA

Drag actions must have single-pointer alternatives.

2.5.8
Target Size (Minimum)AA

Interactive elements must be at least 24×24 CSS pixels.

3.2.6
Consistent HelpA

Help mechanisms must appear in the same location across pages.

3.3.7
Redundant EntryA

Do not make users re-enter information already provided.

3.3.8
Accessible Authentication (Minimum)AA

Do not require cognitive function tests to log in.

3.3.9
Accessible Authentication (Enhanced)AAA

Stricter version with fewer exceptions.

AXS Audit

AXS Audit evaluates your website against the full WCAG 2.2 matrix — visual, cognitive, and keyboard criteria that most automated scanners miss. Built by the same team that created this guide.

Explore AXS Audit