Accessible design is just as important online as it is in the physical world to ensure as many people as possible can work, play, learn, and feel included. But who decides what reasonable digital accessibility looks like and how to achieve it?
That’s what the Web Content Accessibility Guidelines (WCAG), published by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C), are meant to accomplish. The most recent version, WCAG 2.2, was released in October 2023.
We look at the importance of digital accessibility, how businesses can achieve and maintain it, and how it dovetails with consent management. We’ll also dig into how accessibility standards and requirements are evolving with changes in the law and societal expectations. And we’ll explore the WCAG 2.2 specifically — with its highlights and implications for design and development of websites and apps.
Why digital accessibility matters
Digital spaces and tools have become essential for how many people around the world learn, work, create, socialize, and more. We have standards and tools to ensure that as many websites and apps as possible work well with the most systems and devices.
Similarly, we have accessibility standards and legal frameworks to ensure that as many websites and apps as possible work for the largest number of people, regardless of their abilities or accommodation needs.
The World Health Organization (WHO) estimates that about one in six people, about 1.3 billion of us, will experience significant disability in our lifetimes, which is a very large audience to potentially exclude from equity and access online, not to mention a large potential customer base.
A lack of digital accessibility can prevent people from getting educated and staying informed, earning an income, and being a part of social groups. Digital accessibility standards and requirements address and provide accommodation for a variety of physical, cognitive, and other disabilities.
By implementing and maintaining digital accessibility standards, we can help to ensure that online spaces are more fair and welcoming for everyone. While ideally all websites and apps would be designed and maintained using accessibility best practices, in this as in many things, regulation is required to ensure standards are met and maintained. We will look at legal pressures and laws that have been applied to improve digital accessibility, as well as the standards themselves and their evolution.
What is the WCAG 2.2?
WCAG 2.2 is the latest version of the Web Content Accessibility Guidelines recommendations, released in October 2023. The most recent updates to this version came out December 12, 2024. The recommendations build on WCAG 2.0 and 2.1.
WCAG 2.2 addresses accessibility considerations for people with motor disabilities, cognitive and learning disabilities, and low vision. It introduces additional success criteria for web developers, like simplified navigation and text that is easy to understand, to improve accessibility and inclusivity.
There is also a focus on improving consistency of experience across websites, especially for those using assistive technologies. WCAG 2.2 also refines the existing guidelines for clarity and to make implementation easier.
What are the key updates with WCAG 2.2?
The key updates include guidelines with a focus on user customization, reduced reliance on memory, refinements to existing criteria, and new success criteria.
Focus on user customization
This update stresses the importance of enabling users to customize their content experience, making adjustments to text sizes, fonts, colors, and other elements to better meet their needs.
Reduced reliance on memory
This update aims to ensure that users don’t have to remember information across multiple pages. This is particularly meant to assist users with cognitive disabilities who may have difficulty recalling previous actions or interactions, or information they obtained from elsewhere on a website.
Refining existing criteria
These include refinements to existing success criteria from WCAG 2.0 and 2.1 to improve clarity and applicability.
- Improved clarification around focus management: to ensure that changes in focus are managed in a predictable and accessible way, particularly to benefit users relying on keyboard navigation or screen readers.
- Refinements to requirements for visual contrast: to ensure content is sufficiently distinguishable from its background, particularly for users with color blindness or low vision.
WCAG 2.2 new success criteria
New success criteria in WCAG 2.2 aim to improve accessibility for people with cognitive impairments and motor disabilities.
- Consistent help: To ensure consistent help, guidance, and documentation across a website or app, meant to make assistance and instructions easier to locate and follow to reduce cognitive load.
- Pointer gestures: To ensure that users relying on pointer gestures (e.g. via touch or a mouse) can perform the same actions with simple, uncomplicated gestures, particularly to make actions easier for those with motor disabilities.
- Dragging movements: To ensure an alternative means of completing a dragging movement like adjusting a slider, such as via a single tap or click at point A and at point B of the drag, to make such actions easier for those with motor disabilities.
- Focus not obscured: To ensure that focus is never completely hidden or lost behind other content, e.g. when tabbing through a website, such as when a footer is “sticky”.
- Target size: To ensure that interactive targets, such as linked icons, are large enough (at least 24 x 24 CSS pixels) that users are unlikely to miss the target or click the wrong element.
- Accessible authentication: To ensure understandable and easily navigable authentication processes, such as logging in to an account, to reduce confusion and cognitive load for those with cognitive disabilities.
- Redundant entry: To ensure that previously entered information remains available via auto-complete or selection when filling out a form, to prevent the need to re-enter previously provided information.
- Accessible notifications: To ensure when changes on a web page are clearly communicated to users to reduce confusion, like when a new page loads or an error message is displayed, particularly for those with visual or auditory processing disabilities.
Accessibility laws and WCAG 2.2 compliance
Around the world there are a variety of laws to protect people with disabilities, enforce their rights, and facilitate their equitable participation in society. We look at some regulations that are relevant to digital accessibility and with connections to the WCAG.
Americans with Disabilities Act (ADA)
The Americans with Disabilities Act (ADA) is a federal civil rights law enacted in the United States in 1990 to protect American citizens with disabilities from discrimination. It is divided into five sections:
- Title I: Employment
- Title II: Public Services (State and Local Government)
- Title III: Public Accommodations and Services Operated by Private Entities
- Title IV: Telecommunications
- Title V: Miscellaneous Provisions
In April 2024, the Department of Justice updated its regulations for Title II, publishing the Web & Mobile Application Accessibility Rule, which sets technical requirements for state and local governments to follow to ensure that their websites and mobile apps are accessible to people with disabilities.
The ADA doesn’t explicitly reference the WCAG or directly influence the recommendations, but both have similar goals and are updated to reflect changes in the digital landscape to improve accessibility.
Section 508 of the Rehabilitation Act
The Rehabilitation Act of 1973 is a federal law in the United States, and was the first major civil rights law there addressing the needs of people with disabilities. It aims to ensure that individuals with disabilities have equal access to opportunities in public life, such as education, employment, and public services.
Section 508 of the Rehabilitation Act is an amendment from 1998 that requires federal agencies to make their electronic and information technology accessible to people with disabilities. This includes websites, documents, printers or other hardware interfaces like TVs, and desktop or mobile software.
As of June 28, 2025, all businesses will have to be fully compliant with the Act’s accessibility requirements, and enforcement with potential penalties for noncompliance will begin.
EU Web Accessibility Directive
The EU Web Accessibility Directive (WAD) is an EU-wide law that came into force in 2021 to address digital accessibility for websites and mobile apps of public sector bodies and ensure that websites and mobile apps are accessible to people with disabilities.
To ensure a consistent definition of accessibility, the WAD is supported by a harmonized technical standard. Websites or mobile apps that meet all the applicable technical requirements in the standard are assumed to be compliantly accessible under the WAD. The standard has been based on the WCAG 2.1 and the WAD has a specific focus on WCAG 2.1 Level AA compliance. It’s expected that the WAD will be updated to align with the WCAG 2.2.
Why accessibility matters for consent management
We believe that privacy is a human right, as is choice. It’s also codified by an increasing number of laws around the world. This is why it’s important for consent management platforms (CMP) to implement and maintain accessibility standards.
A CMP with poor accessibility excludes users with disabilities, which can be a legal violation in addition to bad user experience that alienates audiences and can negatively impact your business’s reputation.
If a user can’t easily access or read legally required notifications about what data your business collects, why it’s processed, and what their rights are and how to exercise them, legally can their consent be considered informed? If a user can’t easily express choices about what cookie uses they consent to, legally can their consent be considered explicit under laws like the GDPR?
Beyond questions of consent, delivering a worse website experience for some users could be construed as discriminatory, violating requirements of various laws meant to protect users with disabilities.
In addition to legal issues, poor accessibility sends a loud, clear message that your website or app — and by extension, your company — doesn’t care about a substantial audience or their privacy rights, and doesn’t want them as visitors or customers. If a company doesn’t care about that, users may wonder what other legal requirements a company is ignoring or corners they might be cutting.
In some cases, such a lack of accessibility would be a clear signal for people to take their engagement, personal data, and wallets elsewhere. In other cases, there may not be other options, and users would be prevented from doing important things online or exercising their legal rights to privacy and choice.
As outlined above, CMPs need to address a diverse set of needs, whether it’s reducing the cognitive load of navigation, making buttons easy to read and click, or providing a well integrated experience for users relying on assistive technologies. Delivering on these workflows and functions shows attention to detail, respect for the law, care for your audience, and builds trust.
How a WCAG 2.2-qualified CMP like Usercentrics CMPs works
Usercentrics is WCAG 2.1 AA certified, and working toward WCAG 2.2 certification. In addition to our websites, our CMP products meet digital accessibility standards. These include following accessible design principles for user interfaces and consent workflows; testing to ensure compatibility and interoperability with assistive technologies like voice control or screen readers; and flexible, user-friendly interfaces with focus management and enhanced keyboard navigation.
International data privacy laws require that users have easy access to clear notifications about what data is collected, how it’s used, who it may be shared with, and other factors, including what users’ rights are and how to exercise them. To meet digital accessibility standards users with disabilities need to be able to easily find, navigate to, and read or listen to this information in consent banners.
Once informed, users with disabilities need to be able to make choices to accept use of all cookies, some cookies for specific purposes, or deny all but essential cookie use. This requires them to be able to easily find, navigate to, and perform explicit actions like clicking a button or moving a toggle or slider. Many laws also require them (and all users) to be able to return to that functionality to change their consent preferences in the future.
Individuals with disabilities need to be able to access this information and complete these functions as easily as all other users, for all relevant interfaces, including websites, apps, and other connected platforms.
Companies banking on continued growth need to prioritize digital accessibility standards for audiences of all abilities and in all jurisdictions. European users with disabilities need the same access to manage granular consent under the GDPR as users in California do to opt out of the sharing or sale of their personal data, even if they don’t have to provide prior consent in most cases.
Usercentrics Web CMP and App CMP meet WCAG standards to enable your business to provide users with disabilities with an equal and user-friendly website or app experience to get informed about consent and exercise their choices. Meet data privacy and accessibility regulatory requirements, provide great user experience, and build long-term trust with your audience.
