WCAG 2.1 AA and the ADA: what the standard means

In brief

The Title II web rule names WCAG 2.1, W3C Recommendation of 5 June 2018, as its technical standard, at Level A and Level AA. Despite the word "guidelines" in the name, the rule makes meeting the Level A and AA criteria a requirement for public entities.

Under Title III, DOJ points to WCAG as a helpful reference rather than a mandatory standard.

What WCAG 2.1 Level AA includes

Meeting Level AA means meeting all the Level A and Level AA success criteria and the conformance requirements of WCAG 2.1. WCAG 2.1 has 50 such criteria. The checklist has a page for each of them. The six criteria that are new in WCAG 2.2 are not part of WCAG 2.1, so they have no page here.

Criterion 4.1.1 Parsing is part of WCAG 2.1, so it is part of the Title II standard, even though WCAG 2.2 removed it.

What about WCAG 2.2?

The Title II rule names WCAG 2.1. Building to WCAG 2.2 is generally a way to cover WCAG 2.1 as well, but 4.1.1 was removed from WCAG 2.2, so test it separately. Check the rule text for the current standard.

How to use the checklist pages

Each criterion page explains the requirement, who it affects, how to test it, and has code examples for web and mobile. Start with the contrast, keyboard and name, role, value pages.

What to do

• Make WCAG 2.1 Level AA your test target, and record the version in your accessibility policy.
• Include 4.1.1 in your tests.
• Test with both automated tools and manual checks, including a screen reader and the keyboard.

Common mistakes

• Testing only against WCAG 2.2 and skipping 4.1.1.
• Treating Level A alone as enough. The rule names Level A and Level AA.
• Assuming the guidelines are optional because of the name. Under Title II they are a requirement.

Sources

• 28 CFR Part 35, Subpart H: Accessibility of Web Information and Services (eCFR), opens in a new tab
• 28 CFR 35.104: Definitions (eCFR), opens in a new tab
• Guidance on Web Accessibility and the ADA (ADA.gov), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official ADA statute and regulations, and ask a lawyer how they apply to you.