WCAG 2.2 has reached the Candidate Recommendation stage, signaling that organizations should prepare for adoption now to avoid scrambling later. This checklist guides your team through the steps needed to integrate WCAG 2.2 requirements into existing accessibility frameworks without disrupting current conformance programs.
While WCAG 2.2 is a minor update compared to WCAG 2.1, which introduced 17 new success criteria, it still requires significant attention. Each new criterion can create conformance gaps in your digital properties, representing regulatory risk under ADA Title III, Section 508, and similar frameworks that reference WCAG by version number.
Prerequisites
Before using this checklist, ensure your organization has:
- Current WCAG 2.1 Level AA conformance baseline. Complete WCAG 2.1 conformance first, as WCAG 2.2 builds on it.
- Documented conformance testing methodology. Establish a repeatable process that includes automated scans, manual evaluation, and assistive technology testing.
- Clear ownership model for digital properties. Assign ownership for each website, application, PDF library, and email template.
- Access to development, design, and content teams. Your role is to verify accessibility, not implement it.
WCAG 2.2 Conformance Checklist
1. Inventory all digital properties subject to accessibility requirements.
List every website, web application, mobile app, PDF repository, and HTML email system under your accessibility policy. Include third-party platforms where you control content.
2. Identify which success criteria in WCAG 2.2 are new to your conformance target.
Evaluate all new Level A and Level AA criteria if your policy requires Level AA conformance.
3. Assess current conformance against new mobile accessibility criteria.
Test touch target sizing, gesture-based controls, and screen orientation requirements across mobile properties.
4. Evaluate authentication flows against Accessible Authentication requirements.
Test every login form, password reset flow, and multi-factor authentication interface for new authentication-related criteria.
5. Review focus appearance across all interactive components.
Audit focus indicators on buttons, form fields, links, custom controls, and any element that receives keyboard focus.
6. Update your Accessibility Conformance Report template.
Create a new template version that includes rows for all WCAG 2.2 success criteria.
7. Revise procurement language to specify WCAG 2.2 Level AA.
Update contract templates and RFP boilerplate with version-specific WCAG references.
8. Train your conformance testing team on new success criteria.
Ensure testers understand changes and can correctly identify violations of new criteria.
9. Establish a timeline for remediating WCAG 2.2 failures.
Prioritize remediation by risk, focusing on public-facing properties with high transaction volume.
10. Update your accessibility policy to reference WCAG 2.2.
Revise your policy document to specify the version of WCAG you're conforming to.
Common Mistakes
- Treating WCAG 2.2 as optional because it's a "minor version." Each new criterion can generate conformance failures and enforcement actions.
- Waiting for explicit regulatory mandate before adopting WCAG 2.2. By the time a rule explicitly requires 2.2, you're already behind.
- Assuming automated tools will catch new WCAG 2.2 issues. Manual testing protocols are essential for new criteria.
- Skipping the Accessibility Conformance Report update. An outdated template signals you're not maintaining current conformance.
Next Steps
After completing this checklist, schedule a conformance validation audit with your testing team or a third-party auditor. Don't self-certify WCAG 2.2 conformance without independent verification. Document your WCAG 2.2 adoption timeline and share it with executive stakeholders. If significant gaps are found, build a business case for remediation resources now to manage it strategically.
