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WCAG 2.1 vs 2.2: What Your Store, VPAT and Accessibility Statement Should Cite in 2026

Published · 10 min read

WCAG 2.2 is WCAG 2.1 plus nine new success criteria, minus one obsolete one (4.1.1 Parsing). Content that meets WCAG 2.2 also meets WCAG 2.1 and 2.0, and the W3C recommends 2.2 as the target even where a law still names an older version. In practice: test against WCAG 2.2 level AA, and cite the version a law or contract names, alongside 2.2, where one applies, such as WCAG 2.0 AA for an Ontario AODA accessibility report.

This article covers what changed between the two versions, which version each major framework references as of October 2026, how VPAT editions handle it, and how to word an accessibility statement or audit report. For the six new A and AA criteria in detail, and what they mean on a product page and cart, see EN 301 549 V4.1.1 and WCAG 2.2: what changes for online stores.

What changed between WCAG 2.1 and 2.2

WCAG 2.2 became a W3C Recommendation on 5 October 2023 (W3C news). It adds nine success criteria to WCAG 2.1 and makes one obsolete (W3C, What's New in WCAG 2.2):

Criterion Level New in 2.2
2.4.11 Focus Not Obscured (Minimum) AA Yes
2.4.12 Focus Not Obscured (Enhanced) AAA Yes
2.4.13 Focus Appearance AAA Yes
2.5.7 Dragging Movements AA Yes
2.5.8 Target Size (Minimum) AA Yes
3.2.6 Consistent Help A Yes
3.3.7 Redundant Entry A Yes
3.3.8 Accessible Authentication (Minimum) AA Yes
3.3.9 Accessible Authentication (Enhanced) AAA Yes
4.1.1 Parsing (was A) Obsolete and removed

So for a level AA target, the difference is six new criteria (two at A, four at AA) and one removed criterion. Every other success criterion is the same in both versions.

Why 4.1.1 Parsing went. The W3C says assistive technology no longer parses HTML directly, so the criterion no longer serves a purpose, and problems it used to catch now fail other criteria such as 1.3.1 Info and Relationships or 4.1.2 Name, Role, Value (W3C, Understanding 4.1.1; W3C, WCAG 2 FAQ). WCAG 2.0 and 2.1 still contain 4.1.1, but the W3C has added a note that it should be considered always satisfied for content using HTML or XML (W3C, WCAG 2.1 errata).

Is WCAG 2.2 backwards compatible?

Yes, with that one caveat. The W3C says later versions add success criteria and do not change existing ones, and that content that conforms to WCAG 2.2 also conforms to 2.1 and 2.0 (W3C, WCAG 2 Overview; WCAG 2 FAQ). The exception is 4.1.1: a 2.2 audit does not test it, so if someone needs a formal 2.1 or 2.0 conformance claim, 4.1.1 is still part of that version, even though the W3C's note means it is treated as satisfied for HTML.

Three more points from the W3C FAQ are useful when a client asks "which WCAG version should I use?":

  • WCAG 2.2 does not deprecate 2.0 or 2.1. All three remain W3C Recommendations.
  • The working group recommends adopting 2.2 as the conformance target "even if formal obligations mention previous versions".
  • There is no WCAG 2.3 planned. The next major version is WCAG 3, still in development. WCAG 2.2 is also published as ISO/IEC 40500:2025.

Which version each framework references (October 2026)

Laws and procurement standards move slower than the W3C. As of 25 October 2026:

Framework Who it covers WCAG version referenced
US ADA Title II rule (DOJ, 2024) State and local governments WCAG 2.1 AA (June 2018 version)
US ADA Title III Businesses open to the public No regulation sets a version
US Section 508 (2017 refresh) Federal agencies' ICT WCAG 2.0 A and AA
EU: EN 301 549 V3.2.1 Harmonized standard in use today WCAG 2.1 A and AA
EU: EN 301 549 V4.1.1 Published September 2026, not yet cited WCAG 2.2 A and AA
Canada, Ontario (AODA) Public sector, organizations with 50+ employees WCAG 2.0 AA, with exceptions
Canada, Manitoba (AMA) Organizations with 1+ employees WCAG 2.1 AA
UK public sector Public sector websites and apps WCAG 2.2 AA (government guidance)

Some detail on each:

US, ADA Title II. The Department of Justice's 2024 rule requires state and local governments to meet WCAG 2.1 level AA, and it points to the version published in June 2018 (ADA.gov fact sheet). An interim final rule published 20 April 2026 moved the deadlines to 26 April 2027 for entities with a population of 50,000 or more, and 26 April 2028 for smaller entities and special district governments (Federal Register, 91 FR 20902).

US, private businesses. Title II does not cover online stores. For businesses open to the public (Title III), the DOJ says it has no regulation setting detailed web standards, and that businesses have flexibility in how they comply, but must comply (ADA.gov, Guidance on Web Accessibility and the ADA). WCAG is the usual reference point, but no version is set by regulation.

US, Section 508. The 2017 refresh incorporated WCAG 2.0 level A and AA by reference for federal agencies' ICT, and it has not been updated to a later version (Section508.gov, Applicability and conformance; U.S. Access Board). If you sell software to US federal agencies, your 508 report is still measured against 2.0.

EU, EN 301 549. V3.2.1 (2021) uses WCAG 2.1 A and AA and is the edition referenced in the Official Journal today (Implementing Decision (EU) 2021/1339). V4.1.1, published in September 2026, moves to WCAG 2.2, but it only gives a presumption of conformity once the European Commission cites it in the Official Journal. As of 25 October 2026 we found no report that this has happened (NDA Ireland). Our EN 301 549 article covers the timing and the EAA link.

Canada, Ontario. Under the AODA's Integrated Accessibility Standards, public websites and web content posted after 1 January 2012 must meet WCAG 2.0 level AA, except 1.2.4 (live captions) and 1.2.5 (pre-recorded audio descriptions) (Ontario, How to make websites accessible). This applies to designated public sector organizations and to businesses and non-profits with 50 or more employees (Ontario, accessible websites fact sheet).

Canada, Manitoba. The Accessible Information and Communication Standard requires WCAG 2.1 level AA when an organization publishes or updates website content, or launches or significantly refreshes a web application (Accessibility Manitoba).

UK, public sector. GOV.UK guidance says public sector websites and apps should meet WCAG 2.2 AA and publish an accessibility statement (GOV.UK, Understanding accessibility requirements for public sector bodies; GOV.UK Service Manual, Understanding WCAG 2.2). The Government Digital Service has monitored against WCAG 2.2 since October 2024 (GOV.UK, monitoring report 2022 to 2024). This applies to the public sector, not to private online stores.

VPATs and Accessibility Conformance Reports

If you answer RFPs, you will be asked for a VPAT, the template from the Information Technology Industry Council (ITI) that becomes an Accessibility Conformance Report (ACR) once filled in. The current version is VPAT 2.5Rev, dated April 2025, in four editions (ITI, VPAT):

  • WCAG edition: covers WCAG 2.0, 2.1 and 2.2. You report only the versions you actually tested.
  • Revised 508 edition: built on WCAG 2.0, matching Section 508.
  • EU edition: built on EN 301 549, which in this release means WCAG 2.1.
  • INT (international) edition: combines the three, and includes WCAG 2.2.

So yes, a 2.2-based edition exists: the WCAG and INT editions. For a buyer who asks for "a VPAT", the INT edition answers 508, EN 301 549 and WCAG 2.2 in one document. Use the latest template from ITI's page, and expect an EU edition update now that EN 301 549 V4.1.1 is out.

Two habits help reviewers trust an ACR: state the WCAG version and level in the evaluation methods section, and use the VPAT's own conformance terms (Supports, Partially Supports, Does Not Support, Not Applicable) with a remark for anything other than Supports.

What to write in an accessibility statement or audit report

Name the exact version and level, and say how you tested. "We follow WCAG", or a bare claim that a site meets the ADA, tells a reader nothing they can check. A 2.2 AA claim is the most useful default, because it also covers 2.1 AA for everyone who still asks for it.

A short scope line for an audit report:

"Tested against WCAG 2.2 level A and AA, which includes all WCAG 2.1 level A and AA success criteria except 4.1.1 Parsing (removed in WCAG 2.2; the W3C treats it as always satisfied for HTML)."

An example paragraph for an accessibility statement:

"We aim for our store to meet the Web Content Accessibility Guidelines (WCAG) 2.2 at level AA. WCAG 2.2 includes the WCAG 2.1 level A and AA success criteria, except 4.1.1 Parsing, which the W3C has made obsolete. Our most recent review was on [date], using automated checks and a manual review with a keyboard and screen readers. We know of the following issues and plan to fix them by [date]: [list]. If you find a problem, contact us at [email or phone] and we will reply within [number] working days."

A few rules of thumb:

  • Date it. Say when the review happened and when you will review again.
  • List known issues. A statement that names open problems is more credible than one claiming full conformance.
  • Don't promise a legal outcome. Say which guideline you test against, not that the site meets the requirements of a law.
  • Match the requirement you're answering. If an EU buyer asks about EN 301 549, say which edition. Until V4.1.1 is cited, "WCAG 2.2 AA, which covers the WCAG 2.1 AA criteria of EN 301 549 V3.2.1" is accurate.

When a client may still ask for WCAG 2.1

Testing to 2.2 is the sensible default, but expect requests for 2.1 or 2.0:

  • Contracts and RFPs often copy older wording, such as "WCAG 2.1 AA", and the contract is what you'll be measured against. Answer the question as written, then add that you also test to 2.2.
  • Public sector buyers follow their own framework: US state and local bodies cite 2.1 AA, US federal buyers cite 508 (2.0), and Ontario cites 2.0 AA.
  • Existing reports may need a like-for-like re-test so results can be compared with a 2.1 baseline.

In these cases a 2.2 AA audit still answers the question, as long as the report says how it maps to 2.1 (the six added criteria, and 4.1.1). If a contract requires a strict 2.1 conformance statement, check whether 4.1.1 needs its own line.

Sentinela's scans and audits test against WCAG 2.2 level A and AA. An audit can target WCAG 2.1 AA on request, and the report records a verdict for every criterion, so you can show which ones are new in 2.2 (how we test).

This article is general information, not legal advice. For your obligations, talk to a lawyer.

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