WCAG 2.2 AA and UK public-sector accessibility in 2026

The United Kingdom was one of the first countries to make web accessibility a hard legal requirement rather than a courtesy. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 have been in force since September 2019, and the standards they reference have evolved. From October 2024, the technical baseline is WCAG 2.2 Level AA — a meaningful update that public bodies and their suppliers ignore at their peril.

The 2018 regulations apply in full to central government, local authorities, the NHS, maintained schools, further-education colleges, the police and a long list of other publicly funded organisations. The duty extends to anything the body procures, licences or commissions — meaning that an inaccessible third-party product bought by a council is, for accessibility purposes, the council’s problem.

What the regulations actually require

Three concrete obligations sit at the heart of the 2018 regime.

First, every website and mobile application must meet WCAG 2.2 Level AA. The bar is technical, specific and testable. It is not a question of effort or intent; it is a question of measurable conformance against published criteria.

Second, every regulated body must publish an accessibility statement. The statement has to identify the standard the site aims to meet, record the level of conformance achieved, list known issues with timelines for fixing them, explain how a user can request an alternative format or report a problem, and describe the enforcement route if a complaint is not resolved.

Third, the body must put in place a feedback mechanism and a defined enforcement procedure. The Government Digital Service (GDS) maintains a public register of monitored bodies and a process for escalating unresolved complaints to the Equality and Human Rights Commission (EHRC) and, ultimately, to judicial review.

Non-compliance is not theoretical. Local authorities and government departments have faced detailed compliance notices, public criticism and the cost of retrospective remediation. The reputational and operational cost of an enforcement notice usually exceeds the cost of getting it right in the first place.

WCAG 2.2: what changed

WCAG 2.2 was published as a W3C Recommendation in October 2023. The UK government formally adopted it as the technical standard for the 2018 regulations from October 2024. The update is incremental rather than revolutionary, but several new criteria matter in practice:

• Target Size (Minimum) — interactive elements such as buttons and links must be at least 24 by 24 CSS pixels, unless they appear inline in a sentence or have an equivalent alternative. This affects mobile and touch interfaces most directly.
• Dragging Movements — any action that requires dragging must have a single-pointer alternative (for example, a tap-to-place option on a slider).
• Focus Appearance — when a user navigates with a keyboard, the focus indicator must be visible, with a contrast of at least 3:1 against the surrounding background and a minimum size relative to the focused element.
• Consistent Help — repeated help mechanisms (contact details, chatbots, accessibility links) must appear in the same relative location across pages.
• Redundant Entry — users must not have to re-enter the same information in the same process unless re-entry is essential.
• Accessible Authentication — cognitive function tests (such as remembering a password) must have an alternative, and authentication must not require recognition of objects or audio unless an alternative exists.
• User Inconsistencies — data entered in one step of a process (such as a delivery address) should be available in subsequent steps or made auto-populated where possible.

The existing WCAG 2.1 criteria — colour contrast at 4.5:1 for body text, keyboard operability, meaningful alt text, captioned video, 200% resizable text and respect for reduced-motion preferences — remain in full force. WCAG 2.2 is a refinement, not a replacement.

Practical steps for compliance

A sensible programme for a public-sector body or a supplier bidding for public-sector work looks like this:

1. Confirm the regulatory perimeter. Identify which parts of the estate are caught by the 2018 regulations, including legacy applications, third-party portals and embedded content.
2. Audit against WCAG 2.2 AA, not the older 2.1 baseline. Automated tools such as axe DevTools, Lighthouse and Pa11y are useful but catch perhaps a third of common issues reliably. Manual review, including testing with NVDA, VoiceOver and keyboard-only navigation, is essential.
3. Prioritise templates and shared components. Fixing navigation, form patterns and the page chrome raises the whole estate. Per-page tweaks are wasteful when a single component appears in a hundred places.
4. Train content editors, not just developers. Most regressions come from new content — an untagged PDF, a heading skipped by a paragraph, a colour used as the only signal. The training cost is small and the return is durable.
5. Publish a credible statement. A statement that claims full conformance when automated testing flags dozens of issues is worse than one that admits specific gaps and describes a plan. Regulators and the courts take a dim view of statements that bear no relation to reality.
6. Re-test on every release. A short accessibility pass as part of the publishing checklist prevents slow drift.
7. Treat procurement seriously. Contract clauses that bind suppliers to WCAG 2.2 AA, with rights of audit and remediation, are the only way to keep third-party products honest.

Beyond the public sector

Although the 2018 regulations apply only to public-sector bodies, the Equality Act 2010 reaches far further. It makes it unlawful for any service provider — public or private — to discriminate against disabled people, and the courts have shown growing willingness to treat inaccessible websites as indirect discrimination when reasonable adjustments would have fixed the problem. The same WCAG 2.2 AA standard that satisfies the 2018 regulations is a sound basis for any British business that wants to manage its Equality Act risk.

The standards are mature, the test tools are free, and the cost of getting accessibility right is a fraction of the cost of dealing with the consequences of getting it wrong. For public-sector bodies and the suppliers that serve them, WCAG 2.2 AA is the baseline, not the ceiling.