From WCAG 2.1 to 2.2 to 3.0: The Differences That Actually Matter

WCAG 2.2 is the current bar: the version courts and enterprise procurement actually reference. Regulators are one step behind: the DOJ's Title II rule still references WCAG 2.1, a detail that matters and that we get precise about below. WCAG 3.0 is the horizon: a working draft that rethinks the entire model. Knowing the delta between them keeps you from rebuilding twice.

We track both, so our clients don't have to. Here is the honest version: what 2.2 added, what 3.0 changes, and what you should do on Monday morning.

WCAG 2.2 added nine criteria and removed one. Six sit at Level A or AA: the ones that count toward a 2.2 AA conformance claim:

• Focus Not Obscured, Minimum (2.4.11, AA): when something gets keyboard focus, it can't be entirely hidden behind a sticky header or footer.
• Dragging Movements (2.5.7, AA): anything operable by dragging must also work with a single click or tap. No drag path required.
• Target Size, Minimum (2.5.8, AA): tap targets at least 24 by 24 pixels, with narrow exceptions. The only new 2.2 rule automated checkers test.
• Consistent Help (3.2.6, A): contact info, FAQs, chat: same place, same order, on every page.
• Redundant Entry (3.3.7, A): never ask for the same information twice in one session. Auto-fill it or let people pick from what they entered.
• Accessible Authentication, Minimum (3.3.8, AA): logins can't demand a memory test. No remembering passwords from another step, no puzzles. Password managers and paste must work.

One removal: 4.1.1 Parsing. It dated from an era when invalid HTML routinely broke assistive technology; modern parsers made it obsolete. Validity problems that actually break something are now reported under the criterion they break, usually 4.1.2 Name, Role, Value.

The practical takeaway: if you were compliant with 2.1 AA, the gap to 2.2 AA is small, concrete, and very fixable. Five of the six new rules can't even be checked by automated scanners, they need a human looking at the page, which is exactly why our audits pair the AI agent's scan with human review.

WCAG 3.0 isn't an update, it's a structural rewrite. Guidelines become outcome statements ('Users can…'), each backed by testable requirements with explicit scoping, technology-specific methods, and a brand-new mechanism called assertions.

The conformance model changes completely. Gone is pass/fail across 55 criteria. Requirements get tagged by failure severity: physical harm, risk (financial, medical, legal, privacy), barrier, friction. And conformance means meeting all core requirements.

First: Bronze, Silver, and Gold do not replace A, AA, and AAA. They are reporting tiers that reward going beyond conformance, Bronze and Silver add supplemental requirements and assertions, Gold adds organizational assertions. The shorthand has it exactly backwards.

Second: assertions are new as a formal mechanism. Under 3.0, organizational evidence counts: style guides for transcripts, usability testing with people who need captions, published accessibility policies. Process evidence matters, not just code.

Third: the contrast algorithm is still undecided. Every contrast requirement in the draft reads 'to be determined.' APCA is the publicly discussed candidate, but it is not named anywhere in the draft. Anyone telling you 'WCAG 3 uses APCA' is ahead of the spec.

Conform to WCAG 2.2 AA now. It is the current baseline the market recognizes, and in practice it satisfies the legal one. One precision point, since this matters for client-facing copy: the DOJ's Title II rule requires state and local government web content and mobile apps to meet WCAG 2.1 Level AA, not 2.2. The legal mandate is already behind the current standard. Current deadlines, after the DOJ's April 2026 extension: April 26, 2027 for entities serving 50,000 or more people, and April 26, 2028 for smaller governments and special districts. That mandate covers public entities. Private businesses fall under Title III, where there is still no codified technical standard, though WCAG 2.1 AA remains the benchmark most demand letters, settlements, and procurement requirements use. Because WCAG 2.2 AA is a superset of 2.1 AA, with one exception (2.2 removed success criterion 4.1.1, Parsing), building to 2.2 AA satisfies 2.1 AA in practice. Never audit against 3.0 until it is final, tooled, and explicitly adopted; auditing against a draft is how you rebuild twice.

Two cheap moves that are directionally certain whatever 3.0 becomes: write in plain language (the draft's clear-language expectations are only getting stronger), and stop treating accessibility as a code-only exercise, document your process, because 3.0 will ask for the receipts.

That is how we work at Thanos Labs: our Web Accessibility AI agent audits against WCAG 2.2 AA, a human in the loop approves every fix, and we watch 3.0's direction closely, so when the standard moves, our clients are already standing where it's going.