Inclusive Digital Services: A Guide to WCAG 2.2

Shazia Attia - Business Analyst


Digital accessibility ensures that as many people as possible can use the services provided to them and that the available information is understandable. In short, it’s about making things work for everyone.

As a Business Analyst at Invuse, I aim to create a digital world with no barriers, regardless of ability, so everyone can participate fully and independently. Digital inclusion, accessibility and usability ensure we are enabling online experiences for all.

If a website or mobile app is not accessible then it simply is not usable. However, having a usable site does not mean it is accessible.​ Having both is the only way we are going to create an inclusive web.

Our design choices will either enable or disable our users. Not only are we considering users who may have a permanent and/or visible disability, but also those who may not be able to use the website due to their situational circumstances.

Accessibility is being able to access a website regardless of ability or needs.

The WCAG 2.2 changes, how it will affect you and next steps

Web Content Accessibility Guidelines (WCAG) is legislation introduced in September 2018 for public sector bodies that have public-facing websites and mobile apps.

WCAG 2.2 has now been officially published and it is important you are prepared and aware of the changes.

The Government Digital Service (GDS) monitors public sector bodies’ compliance on behalf of the Minister for the Cabinet Office, failing to comply with the new and existing accessibility standards means your service is not legally compliant and could result in your organisation being formally investigated by regulatory bodies, leading to penalties and reputation damage.

What does WCAG 2.2 means for council web content leads?

Currently, all local authorities are required to conform to the WCAG 2.1 AA standard. However, WCAG 2.2 AA will become the new public sector websites and apps standard. As a former Council employee who was responsible for the accessibility of the corporate site and mobile app, the publication of WCAG 2.2 would have meant starting the preparatory work behind the scenes. It is important to highlight that even though GOV.UK will not be monitoring for the extra criteria until October 2024, it is worthwhile to begin understanding the new success criteria and how the changes can affect your site.

So what actions would I have taken?

Well, I would have first tried to understand the new nine criterions, broken these down in plain English and started thinking about how these changes would impact the site as well as my demographic of users.

The 9 WCAG Changes in plain English

2.4.11 Focus Not Obscured (Minimum) - Level AA

2.4.12 Focus Not Obscured (Enhanced) - Level AAA

Hidden keyboard focus – Sighted users who depend on a keyboard to navigate the web page will no longer find that the component and focus indicator are overlapped by other content such as cookie pop-ups, sticky headers or non-modal dialogues.

Level AA – at least some of the element with focus is visible
Level AAA – all of the component and its focus indicator is visible

2.4.13 Focus Appearance - Level AAA

Point of focus – Sighted users who depend on a keyboard to navigate the web page will visually be able to tell where the keyboard focus is.

2.5.7 Dragging Movements - Level AA

Alternative to drag and drop – Users with motor disabilities will no longer struggle with having to use precise motion and keep pressure on the mouse button or touch screen to complete drag and drop actions.

2.5.8 Target Size (Minimum) - Level AA

Bigger buttons – Users who struggle with fine motor skills will be able to interact with elements such as buttons without accidentally activating the wrong element.

3.2.6 Consistent Help - Level A

Help on a website – Users and those with cognitive disabilities will be able to find the help they need such as contact information or self-help options, in a consistent manner across the site.

3.3.7 Redundant Entry - Level A

Help on a website – Users and those with cognitive disabilities will be able to find the help they need such as contact information or self-help options, in a consistent manner across the site.

3.3.8 Accessible Authentication (Minimum) - Level AA

3.3.9 Accessible Authentication (Enhanced) - Level AAA

Logging in alternatives – Many users struggle with logging into accounts including transcribing authentication codes sent to a device into the web page which is prone to errors. Users with motor disabilities or cognitive issues such as memory, dyslexia, and dyscalculia will find it helpful for example to be able to copy and paste their password from 3rd party password management tools.

Success Criterion 4.1.1

Parsing will be completely removed as assistive technology no longer needs to directly parse HTML.

Depending on functionality and features available on council sites, in my opinion, the most relevant criteria include focus not obscured for cookie banners or pop-ups, target size for mobile apps, consistent help across the site, and redundant entry for any online forms.

Lastly, from a council point of view, I would like to highlight that if 2.1 AA is not being met then it is imperative that takes priority over 2.2 AA. This includes spending time and resources on PDFs and documents on the site as well as accessibility on social media sites.

Next steps

Some of the new criteria in WCAG 2.2 can be complicated to test for and will require a certain level of in-depth inspection; this is where we can help.

With a background in local government and an understanding of time and resource constraints, we can test and highlight any accessibility issues that may arise, giving you a head start on identifying how the new requirements will impact your digital content

Working towards the work that will be done by the GOV.UK Design System, we want to ensure we are helping you measure what meeting WCAG 2.2 looks like by using a consistent approach.

How we can help

Find out how our Accessibility Health Check can start your journey towards a more connected and inclusive community.