The Web Content Accessibility Guidelines – the ADA’s Requirements for Digital Content

This month, WCET is placing a spotlight on digital accessibility, with a particular focus on the newly updated requirements for public entities, including higher education institutions. We kicked off the month with an overview of the recent ADA updates, and today, we are thrilled to continue along this theme.

A warm welcome and heartfelt thanks to Jared Smith, Executive Director of WebAIM, for joining us today. Jared offers an exceptional overview of the guidelines that the ADA will use as the standard for digital content accessibility.

Be sure to stay tuned to WCET for more expert insights on accessibility in upcoming Frontiers posts. WCET members, we’re eager to connect with you at this month’s Closer Conversation, where we’ll be discussing plans to meet these new regulations. Plus, don’t forget to check out our latest member-only resource: Access for All: New Accessibility Rules for Public Entities. SAN members can download it here, and WCET members can access it here.

Thank you once again to Jared and the WebAIM team for today’s post. This is a the time to prioritize digital content accessibility—not just to comply with updated regulations, but to ensure that all learners can fully engage with the innovative resources and tools available today. Here at WCET, we admire the work of WebAIM, and we are committed to helping to advance the mission to bring digital learning to everyone.

Enjoy the read,

Lindsey Downs, WCET

---

Earlier this month, WCET Frontiers shared how the ADA will begin requiring public entities to meet WCAG 2.1 A and AA success criteria as early as April of 2026.

This update to the ADA provides much-needed clarification of how discrimination for digital products can be measured. The US Department of Health and Human Services has issued a similar update to Section 504 regulations requiring WCAG 2.1 A/AA conformance for digital content in a wide array of health and human services.

What is WCAG?

The Web Content Accessibility Guidelines (WCAG) are a set of international recommendations for digital accessibility. The guidelines are published by the World Wide Web Consortium or W3C. It’s important to recognize that WCAG itself is not a legal standard and it is not developed by the US government.

These technical guidelines are instead generated by representatives of interested W3C member organizations and invited experts – professionals who are interested in making the web more accessible to individuals with disabilities.

WCAG is not new. The first version of the guidelines, WCAG 1.0, was finalized 25 years ago in 1999. The guidelines were updated significantly in 2008 to version 2.0. In 2018, the 2.1 sub-version was finalized, and in 2023, version 2.2 was completed. WCAG 2.1 and 2.2 make very minimal changes to the requirements found in WCAG 2.0, but instead add new requirements to reflect modern innovation on the web, including mobile apps and devices and accessibility for users with cognitive and learning disabilities.

WCAG Conformance

WCAG is structured based on four main principles:

1. Perceivable,
2. Operable,
3. Understandable,
4. Robust.

These guiding principles provide a foundation to ensure that content:

• can be received by a user’s senses,
• can be navigated and operated,  
• is likely to make sense, and,
•  will work with the end user’s technology and assistive technology.

Within the WCAG principles are 13 high level statements about accessibility called guidelines. Examples of WCAG guidelines are “Provide text alternatives for any non-text content” and “Make all functionality available from a keyboard” – wonderful suggestions for making content accessible, but not very measurable.

Within the guidelines are success criteria which are measurable, pass/fail statements about accessibility. Success criteria require that images have alternative text, captions are provided for videos, form inputs are properly labeled, text has sufficient contrast, and much more.

Success criteria are where conformance with WCAG is measured. Each success criterion is assigned a level: A, AA, or AAA. The levels do not always align with end user impact, but in general, here is an overview:

• When level A success criteria are not met there will likely be notable barriers to end users with disabilities.
• When level AA success criteria are not met, then some users will likely have difficulty or frustration accessing the content.
• Meeting the level AAA success criteria can provide benefit to many users with disabilities, but these success criteria are often more difficult to meet or may not be relevant or appropriate for some types of digital content. This is currently the highest standard to reach, however, it does not mean that all content will meet the needs of all end users.

The principles -> guidelines -> success criteria structure of WCAG results in each success criterion having a number designation. As an example, success criterion 2.4.3, which requires that navigation order be logical, is the 3^rd success criterion in the 4^th guidelines under the 2^nd principle.

For a page or other digital product to meet the ADA technical requirements it, including any 3^rd party content within that page or product, must fully meet all WCAG level A and level AA success criteria.

WCAG and the ADA

Because WCAG is the most common measure of digital accessibility, it has been a de facto standard for the ADA for many years. Many ADA and related lawsuits reference WCAG. The Department of Justice and other entities have long indicated that WCAG is a preferred measure of discrimination.

This year’s update to the ADA codifies WCAG 2.1 A/AA as being the technical standard for public entities. While WCAG 2.2 is the current version of WCAG, the new success criteria in version 2.2 are not legally required. Similarly, while AAA success criteria can be very beneficial to some users with disabilities, digital products are not required by the ADA to meet any AAA success criteria. This update to the ADA applies only to public entities, such as most higher education institutions, but these guidelines may be applied to private entities in the future.

Resources

WebAIM has found that accessibility barriers are pervasive on the web. While higher education web sites fare better than most others, barriers to users with disabilities and non-conformance with the Web Content Accessibility Guidelines are widespread. With ADA soon requiring WCAG A/AA conformance, institutions must begin now to formulate or accelerate plans to full implement these guidelines.

Because WCAG is a technical specification with sometimes confusing or ethereal language, it can be daunting and overwhelming. WebAIM’s WCAG Checklist provides a simplified presentation of the guidelines. The WebAIM web site has many materials to help you better understand, implement, and measure accessibility. The WAVE accessibility testing tools can be used to measure many aspects of WCAG conformance.

Post written by Jared Smith – Executive Director, WebAIM

---