What this guide covers
What are the WCAG guidelines, and which version applies to you?
The Web Content Accessibility Guidelines (WCAG) are the shared technical standard for accessible web content. The World Wide Web Consortium (W3C) publishes them through its Web Accessibility Initiative. It appears as WCAG 2.0, 2.1 and 2.2, with a draft 3.0 in progress.
“Content that conforms to WCAG 2.2 also conforms to WCAG 2.1 and WCAG 2.0.”
W3C
So a site built to 2.2 stays inside a rule that names 2.1. The W3C WAI overview of WCAG lists every version.
WCAG 3.0 is a Working Draft dated September 10, 2026. The W3C says it “does not deprecate WCAG 2” and gives no dated timeline. The HHS rule names 2.1, so 3.0 is not your target.
Two other governments use the same standard, and neither applies to a US nonprofit. The gov.uk guidance says UK public sector sites must meet WCAG 2.2 AA, and India’s GIGW 3.0 is based on WCAG 2.1 Level AA.
Write down which version your funder’s rule names (2.1) and which version you build to.
WCAG 2.0, 2.1 and 2.2 guidelines compared
| Version | First published | Status | Referenced by |
|---|---|---|---|
| WCAG 2.0 | December 11, 2008 | Content that conforms to 2.2 also conforms to 2.0 | Section 508 refreshed standards are harmonized with 2.0 |
| WCAG 2.1 | June 5, 2018 | W3C Recommendation, current edition May 6, 2025 | HHS Section 504 rule (45 CFR 84.84) |
| WCAG 2.2 | October 5, 2023 | W3C Recommendation, December 12, 2024 | Not named by the HHS rule |
| WCAG 3.0 | Draft | Working Draft, September 10, 2026 | Not named by the HHS rule |
What changed between versions:
WCAG 2.1 adds 17 success criteria.
WCAG 2.2 adds 9 success criteria.
WCAG 2.2 removes 4.1.1 Parsing, which the W3C calls obsolete.
How do the WCAG guidelines work?
The standard is layered. Four principles sit at the top, guidelines sit under them, and success criteria sit under the guidelines.
The four principles, known as POUR, are Perceivable, Operable, Understandable and Robust.
Guidelines state the basic goals under each principle. WCAG 2.0 has 12 guidelines, and WCAG 2.1 and 2.2 have 13. Success criteria are the testable part. Each is a testable statement rated Level A, AA or AAA.
Principles at the top, guidelines beneath them, success criteria beneath those
Pick one page and name one success criterion it must meet. If you cannot, the target is not yet specific.
How do conformance levels A, AA and AAA work?
Level AA means meeting the Level A and Level AA success criteria, which is how the HHS rule words it.
| Level | What you meet |
|---|---|
| Level A | A criteria |
| Level AA | A + AA criteria |
| Level AAA | A + AA + AAA |
Section 5.2 of WCAG 2.2 sets five conformance requirements:
Conformance level.
You choose A, AA or AAA.
Full pages.
“Conformance is defined for web pages, not for portions of web pages.”
Complete processes.
A process conforms as a whole.
Accessibility-supported ways of using technologies.
Only these count toward conformance.
Non-interference.
The fifth requirement, section 5.2.5.
Complete processes matter most for a donation path. Section 5.2.3 reads:
“When a web page is one step in a process toward completing an activity, all web pages in the process conform to the specified level or better.”
WCAG 2.2, section 5.2.3
A donation flow that runs across several pages conforms as a whole or not at all.
Level AAA is not what the HHS rule names. WCAG 2.2 section 5.2 says:
“It is not recommended that Level AAA conformance be required as a general policy for entire web sites”
“even content that conforms at the highest level (AAA) will not be accessible to individuals with all types, degrees, or combinations of disability.”
WCAG 2.2, section 5.2
A fix can fall out of conformance when content or plugins change afterward. WCAG says nothing about maintenance. Conformance is judged on the page as it is now, and a later edit, an update or a new form can change that.
List your full pages and complete processes, donation path first. A page you cannot list is a page you cannot test.
What does the HHS rule require, and by when?
The rule is 45 CFR 84.84(b). In part, it requires a recipient to:
“comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1.”
45 CFR 84.84(b)
That duty carries an unless clause. A recipient does not have to comply where it can demonstrate that compliance would fundamentally alter a program or activity, or impose undue financial and administrative burdens. Whether that applies to you is a question for you and your counsel.
The dates depend on headcount. HHS extended both dates in May 2026, and the rule text on eCFR carries the current ones:
Section 84.85 lists five exceptions. In paraphrase:
Archived web content.
Preexisting conventional electronic documents, unless they are used for program access.
Third-party content, except under contractual arrangements.
Password-protected individualized documents.
Preexisting social media posts.
Section 508 is a different law
Section508.gov says: “The law applies to all federal agencies when they develop, procure, maintain, or use electronic and information technology.” It does not bind a funded nonprofit through funding. Your obligation comes through Section 504. The Section508.gov laws and policies page sets out the scope.
Confirm your employee count against the 15 threshold and write the date into the grant file.
What do the WCAG contrast guidelines require?
Three success criteria in WCAG 2.2 set contrast ratios:
| Criterion | Level | Requirement |
|---|---|---|
| 1.4.3 Contrast (Minimum) | AA | At least 4.5:1 for normal text, at least 3:1 for large-scale text |
| 1.4.6 Contrast (Enhanced) | AAA | At least 7:1 for normal text, at least 4.5:1 for large-scale text |
| 1.4.11 Non-text Contrast | AA | At least 3:1 against adjacent color(s) for interface components and graphical objects |
Large-scale text is defined as “at least 18 point or 14 point bold” in the W3C definition, with an equivalent size for Chinese, Japanese and Korean fonts.
For a Level AA target, 1.4.3 and 1.4.11 apply. 1.4.6 does not.
Check your button and body text colors against these ratios with any contrast checker, and write down the results per page template.
What should you do before your compliance date?
The date can feel far away. Separate the date from the work. Starting late means paying for remediation twice, which is the piece’s own reasoning and not a rule.
Confirm which date is yours.
Verify: the date is in the grant file.
Name the target as WCAG 2.1 Level AA, not AAA and not 3.0.
Verify: the target is written in one sentence in your plan.
List full pages and complete processes, donation path first.
Verify: the list exists and each item has an owner.
Check which content falls under the 84.85 exceptions and which does not.
Verify: each exception is checked against the rule text, and the call is yours and your counsel’s.
Decide who operates the site after remediation, so content edits do not undo the fix. This is the piece’s own view.
Verify: a named person or vendor owns every edit to the donation path.
Keep the site operated after the fix.
For ongoing WordPress maintenance, NoDrama keeps WordPress, plugins and themes current, backs up offsite, monitors the site, and includes reporting.
What do people get wrong about the WCAG guidelines?
Four readings of the WCAG accessibility guidelines are easy to get wrong around the HHS date.
“We should wait for WCAG 3.”
It is a Working Draft, and the rule names 2.1.
“The deadline moved, so the requirement relaxed.”
The dates moved. The standard named did not change. The rule still names WCAG 2.1 Level A and Level AA.
“We need AAA.”
The W3C does not recommend requiring Level AAA as a general policy for entire websites, and the HHS rule names Level A and Level AA.
“A scan result means we conform.”
Section 5.2 defines conformance for full pages and for complete processes.
What this guide does not solve
- Whether your organization is a recipient, and how headcount is counted. Those are questions for you and your counsel.
- Other federal rules, including ADA Title II. They are out of scope, and this is not legal advice.
- An audit, or conformance itself. This guide does not test a site or confer conformance, and NoDrama does not offer accessibility audits or remediation.
Conclusion: what the WCAG guidelines ask of your site
The WCAG guidelines are the W3C’s standard, tested through success criteria. Level AA is the level in play, and the HHS rule names WCAG 2.1 with a date set by headcount. Conformance is judged per full page and per complete process, and it holds only while someone operates the site.