Contents
- 01
Know what the standard is
- 02
- 03
What do the WCAG 2.1 AA standards require?
Meeting WCAG 2.1 Level AA means meeting every Level A criterion and every Level AA criterion, in full. W3C’s guidance on conformance states the test as “One of the following levels of conformance is met in full.” That applies to full pages and complete processes.
Tallying the WCAG 2.1 spec gives 30 Level A criteria and 20 Level AA criteria, so 50 in all. Level AAA is not part of AA.
45 CFR 84.84(b)Recipients must “comply with Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1.”
That is HHS’s rule, 45 CFR 84.84(b). WCAG 2.2 is not the HHS standard.
How WCAG 2.1 is built: principles, guidelines and success criteria
Level AA conformance: A and AA together
Four principles
WCAG 2.1 is built on four principles. W3C’s text defines three of them like this:
The fourth principle is Robust.
Thirteen guidelines
The principles divide into 13 guidelines. Guidelines carry no level. Only success criteria do.
| Principle | Guidelines |
|---|---|
| Perceivable | 1.1 Text Alternatives1.2 Time-based Media1.3 Adaptable1.4 Distinguishable |
| Operable | 2.1 Keyboard Accessible2.2 Enough Time2.3 Seizures and Physical Reactions2.4 Navigable2.5 Input Modalities |
| Understandable | 3.1 Readable3.2 Predictable3.3 Input Assistance |
| Robust | 4.1 Compatible |
Three levels
Each success criterion is a testable statement under a guideline, rated A, AA or AAA. AA includes all of A, and AAA is not required for AA. Examples of AAA criteria are 1.4.6 Contrast (Enhanced), 2.5.5 Target Size and 3.1.3 Unusual Words.
The W3C WCAG 2.1 specification is the primary source for every criterion named here. For the levels in general, see WCAG standards and conformance levels explained.
The 20 Level AA criteria in WCAG 2.1
These are the 20 Level AA success criteria, with the numbers and names W3C gives them:
W3C’s Quick Reference shows how specific two of them get. Criterion 1.4.3 sets “a contrast ratio of at least 4.5:1, except for the following:” and exceptions apply, which we do not list here. Criterion 1.4.10 includes the line “Vertical scrolling content at a width equivalent to 320 CSS pixels;” as part of its text.
In our description, 1.4.11 concerns controls and graphics, and 2.4.7 concerns keyboard focus being visible. Level A, which has 30 criteria, covers the basics, such as text alternatives (1.1.1), keyboard access (2.1.1) and name, role, value (4.1.2). We do not list all 30 here.
What WCAG 2.1 added over WCAG 2.0
W3C’s New features in WCAG 2.1 lists 17 new success criteria:
So AA gained 12 criteria over 2.0:
- 2.1.4Character Key Shortcuts
- 2.5.1Pointer Gestures
- 2.5.2Pointer Cancellation
- 2.5.3Label in Name
- 2.5.4Motion Actuation
- 1.3.4Orientation
- 1.3.5Identify Input Purpose
- 1.4.10Reflow
- 1.4.11Non-Text Contrast
- 1.4.12Text Spacing
- 1.4.13Content on Hover or Focus
- 4.1.3Status Messages
By our reading, they cluster around mobile and touch, zoom and low vision, and status messages. W3C does not group them that way. A checklist built for 2.0 does not include them.
Section508.gov puts Section 508’s WCAG 2.0 baseline at “38 applicable WCAG success criteria.” Adding the 12 new criteria gives 50, which matches the Level A and AA tally. That sum is our arithmetic on two sourced numbers.
How WCAG 2.1 relates to WCAG 2.2 and Section 508
The WCAG standards are versioned, and W3C’s WCAG overview gives the publication dates:
“content that conforms to WCAG 2.2 also conforms to WCAG 2.1 and WCAG 2.0.”
W3C
One difference matters: 4.1.1 Parsing is “obsolete and removed from WCAG 2.2.” It is still a 2.1 Level A criterion, so a 2.2 checklist will not test it.
W3C also says, “W3C encourages you to use the latest version of WCAG.” The HHS rule names 2.1, so 2.1 is the version to read for the rule.
Section508.gov describes WCAG 2.0 Level A and AA for federal agency content. We did not find a source stating that Section 508 binds grant recipients, so for an HHS-funded nonprofit the HHS rule is the source to read. The two are not the same standard.
What a WCAG checker can and cannot tell you
A WCAG checker is an automated evaluation tool. W3C WAI’s guidance on selecting evaluation tools says:
WebAIM makes the same point: “Absence of detected errors does not indicate that a page is accessible or conformant.”
A checker still earns its place. It finds obvious failures fast.
If you run one, treat each flagged item as a lead to check by hand, and treat a clean result as not a conformance result.
A site also changes after any review, and someone has to operate it. NoDrama’s plans include “WordPress, plugins and themes kept current” and visual regression testing, which compares how pages look and is not a WCAG test. NoDrama does no accessibility work. For the maintenance side, see what NoDrama’s WordPress maintenance covers.
See what NoDrama’s plans include.
They cover updates, backups and monitoring, and no accessibility work.
Common misreadings of the WCAG 2.1 AA standards
What this does not solve
This guide is not an audit and not legal advice, and it does not tell any organization whether it conforms. Whether HHS’s rule reaches your organization depends on funding and headcount, and counsel or the funding agency confirms that. How employees are counted for the two headcount tiers is also a question for them. NoDrama’s plans include no accessibility, WCAG, ADA or Section 508 work.
Conclusion: 50 criteria, met in full
The WCAG 2.1 AA standards mean all 30 Level A and all 20 Level AA success criteria, met in full on full pages and complete processes. HHS’s rule names WCAG 2.1, and content that conforms to 2.2 also conforms to 2.1. WCAG 2.1 added 12 criteria at A and AA over 2.0, so a 2.0 checklist falls short. A checker finds leads and does not return a conformance result. Whether the rule reaches an organization is a question for counsel or the funding agency.