WCAG 2.2 AA and the European Accessibility Act

AA means every A and AA criterion passes, and a clean axe run proves only the part a machine can check.

Before you read: predict

ExamHall's exam page keeps its timer bar at the top of the window with position: sticky; the bar is 80 px tall. The team's CI runs axe-core 4.14.0 on the page with every WCAG 2.0, 2.1 and 2.2 A and AA tag. A candidate has scrolled down until Answer 4's input sits just under the timer bar. Her cursor is in Answer 5's input, and she presses Shift+Tab.

What happens, and what does axe report on the page in that state?

The 30-second version

WCAG 2.2 Level AA is the usual bar: every Level A and AA criterion passes. 2.2 adds focus that sticky bars cannot hide, 24-pixel targets, a click path for every drag, and sign-in without memory tests. The EU's Accessibility Act has applied since 28 June 2025; Europe's standard equals WCAG 2.1 AA, which 2.2 covers. Tools catch only part.

AA means every A and AA criterion passes, and a clean axe run proves only the part a machine can check.

How it works

Step 1 of 12

The bar. WCAG 2.2 sorts testable success criteria under four principles: perceivable, operable, understandable, robust. Each criterion has a level: A, AA or AAA.

In the kitchen

techniques grouped four ways, each listed for a belt → criteria under four principles, each with a level (step 1)

Analogy: A judo club's belt grading (combat sport)

The national federation's syllabus lists techniques under four groups, and each belt adds its own list.

At the grading	In the standard
techniques grouped four ways, each listed for a belt	criteria under four principles, each with a level (step 1)
a brown-belt candidate shows every lower belt's techniques and the brown list; one missed yellow technique fails brown	AA needs every A and AA criterion (step 2)
the new syllabus keeps the old lists, adds a few techniques and retires one	2.2 adds nine criteria and removes 4.1.1 (step 3)
from a set date the sports council lets only clubs with brown-belt coaches teach, naming no edition itself	the Act's date, conformity presumed through a standard (steps 9–10)
the club's camera app counts clean landings, but not whether the thrower kept hold of the partner's sleeve	axe checks some criteria; people check the rest (step 11)

In real terms: a level is a full list, not a score, and a newer list includes the older one.

Breaks down when: a grading happens once. A product changes every release, so the checks run again each time (step 12).

Contrasting case: WCAG 2.2's AAA criteria, such as 44 by 44 targets (2.5.5) or no object-recognition test at sign-in (3.3.9). They go beyond AA, and the Act's yardstick does not require them.

Examples, run for real

4.1 ExamHall EXH-3400: a code the candidate cannot paste

ExamHall's exam login asked for the access code emailed to each candidate, in six one-digit boxes. A paste handler called preventDefault(), "so codes are typed, not shared". MR !3700 lets the first box take a pasted code and spread its digits, with autocomplete="one-time-code":

EXH-3400 six one-digit boxes, paste blocked:  the candidate pastes 482913 from her email -> boxes read ______ (she must type the code)
MR !3700 paste allowed, one-time-code hint:    the candidate pastes 482913 from her email -> boxes read 482913
axe-core 4.14.0, every WCAG A and AA tag, both versions: no violations

Copying six digits by hand is transcription, a cognitive function test; blocking paste removed the helper 3.3.8 names (step 8). axe passed both versions (step 11), so only a manual paste test caught it.

4.2 Streaming: a subtitle editor's sticky toolbar

A streaming service's subtitle editor keeps a 64 px toolbar at the top with position: sticky. The editor has scrolled until Cue 3 sits under the toolbar; from Cue 4, Shift+Tab:

as shipped:                            Shift+Tab to Cue 3 -> no scroll · Cue 3 hidden under the toolbar (0 of 15 points visible) · axe: no violations
with html { scroll-padding-top: 64px }: Shift+Tab to Cue 3 -> the page scrolls up · Cue 3 fully visible (15 of 15 points) · axe: no violations

scroll-padding-top tells the browser the top 64 px do not count as visible, so it scrolls the cue clear (steps 4–5). "Visible" is a hit test: 15 points across the cue, each checked with document.elementFromPoint.

Try it

Answer first, then check. Nothing is saved.

Question 1 of 7

A video player has three control-bar layouts, each with Captions, Settings and Full screen icon buttons; every button has an aria-label. Bar 1: each button 20 by 20 CSS px, 8 px apart. Bar 2: each 20 by 20 CSS px, 2 px apart. Bar 3: each 32 by 32 CSS px, touching (0 px apart). The team runs axe-core 4.14.0 with the wcag22aa tag.

Which bars does its target-size rule report?

Question 2 of 7

A box office's "My shows" list lets a fan reorder shows only by dragging a row's handle (press, slide, release). The team's test list reads Macbeth, Carmen, Hamlet, and the test puts Hamlet first.

Which change in the MR under review makes reordering meet 2.5.7 Dragging Movements?

Question 3 of 7

A payments ledger's sign-in team weighs three steps for its next release.

Under WCAG 2.2 Level AA, which step fails Accessible Authentication (Minimum), 3.3.8?

Question 4 of 7

A team chat's room page failed a manual review on four points: the Send button is an icon with no text or label; the "Online" status text is light grey (#aaa) on white; the composer bar fixed to the bottom of the window hides the "Jump to latest" link when it takes focus; and reactions can only be added by dragging an emoji onto a message. CI runs axe-core 4.14.0 on the page with every WCAG 2.0, 2.1 and 2.2 A and AA tag.

Which of the four does it report?

Question 5 of 7

The interviewer says: "Tell me how you would get ExamHall's candidate app to WCAG 2.2 AA, and how you would keep it there".

Write your answer to the interviewer in at most 150 words.

Your answer (optional, stays on this page)

Question 6 of 7

A German online bookshop has 40 staff and €6 million annual turnover. It sells e-books and print books to consumers through its website, an e-commerce service under the European Accessibility Act (Directive (EU) 2019/882).

From when has the Act's national law required the shop to meet its accessibility requirements?

Question 7 of 7

A streaming service's episode page meets every WCAG 2.2 Level A success criterion, and every Level AA criterion except 2.5.8 Target Size (Minimum): its episode-list buttons are 18 by 18 CSS px and packed tight. There is no alternate version of the page.

Which conformance level can the page claim?

Go deeper

Pro tips

Ask your checker what it checks: axe.getRules(['wcag22aa']). When: someone says "axe is green, so we meet 2.2 AA" (step 11). Verify (RAN, Chromium 153.0.8010.12, axe-core 4.14.0, tips.mjs):
```
tip 1 axe.getRules (axe-core 4.14.0): wcag22aa -> target-size · wcag2411 -> none · wcag257 -> none · wcag338 -> none · all rules 105
```
Test 2.4.11 in your end-to-end suite: after each Tab, hit-test the focused element. A box check misses a bar painted over the element; document.elementFromPoint sees what the user sees. When: a page has a sticky or fixed bar (steps 4–5). Even a field the browser does scroll to lands at the window's top edge, under the bar. Verify (RAN, tips.mjs, ExamHall's exam page, Answer 8 focused, then Shift+Tab to Answer 1):
```
tip 2 7 Shift+Tabs from Answer 8, no scroll-padding: focused input hidden at 2 of 7 steps (a6, a3) · with html { scroll-padding-top: 80px }: 0 of 7
```

Source

Valid as of 2026-10-09.

W3C, Web Content Accessibility Guidelines (WCAG) 2.2 (the row's first source), https://www.w3.org/TR/WCAG22/ (w3c-wcag22.txt). "four principles that provide the foundation for web accessibility: perceivable, operable, understandable, and robust" (step 1); "For Level AA conformance, the web page satisfies all the Level A and Level AA success criteria" (step 2); "Content that conforms to WCAG 2.2 also conforms to WCAG 2.0 and WCAG 2.1." (step 3); 2.4.11: "the component is not entirely hidden due to author-created content" (step 4); 2.5.8: "The size of the target for pointer inputs is at least 24 by 24 CSS pixels" and "if a 24 CSS pixel diameter circle is centered on the bounding box of each, the circles do not intersect another target or the circle for another undersized target" (step 6); 2.5.7: "can be achieved by a single pointer without dragging, unless dragging is essential" (step 7); 3.3.8: "A cognitive function test (such as remembering a password or solving a puzzle) is not required for any step in an authentication process" and "copy and paste to reduce the cognitive burden of re-typing" (step 8); "to be testable with a combination of automated testing and human evaluation" (step 11). W3C Recommendation, as of 2026-10-09.
W3C WAI, What's New in WCAG 2.2 (the row's second source), https://www.w3.org/WAI/standards-guidelines/wcag/new-in-22/ (w3c-new-in-22.txt): "WCAG 2.2 provides 9 additional success criteria since WCAG 2.1." and "4.1.1 Parsing is obsolete and removed from WCAG 2.2" (step 3); "For any action that involves dragging, provide a simple pointer alternative." (step 7).
EUR-Lex, Directive (EU) 2019/882 (European Accessibility Act) (the row's third source), https://eur-lex.europa.eu/eli/dir/2019/882/oj (eurlex-eaa-2019-882.txt): "They shall apply those measures from 28 June 2025." (Art. 31(2), step 9); among the services in scope, "consumer banking services;", "e-books and dedicated software; and" and "e-commerce services." (Art. 2(2), step 9); "Microenterprises providing services shall be exempt from complying with the accessibility requirements" (Art. 4(5), step 9); "shall be presumed to be in conformity with the accessibility requirements of this Directive" (Art. 15(1), step 10). In force as of 2026-10-09.
ETSI/CEN/CENELEC, EN 301 549 V3.2.1 (2021-03), Accessibility requirements for ICT products and services (a standard; not named by the row), https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf (etsi-en-301-549-v3-2-1.txt): "Conformance with W3C Web Content Accessibility Guidelines (WCAG 2.1) [5] Level AA is equivalent to conforming with all of clauses 9.1 to 9.4 and the conformance requirements of clause 9.6" (step 10). The standard calls itself "one voluntary means of conforming to the essential requirements of Directive 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies" and does not name Directive 2019/882; whether any edition is cited in the Official Journal under the Act was not verified (CL-124), so no item is keyed on it.

Checked against the tools and docs as of 2026-10-09.

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