Compliance and accessibility By Partha Biswas and Deepti Karn Last updated on October 6, 2026 7 min read

WCAG guidelines: standards and conformance levels

Diagram of the WCAG guidelines structure: four principles, guidelines beneath them, and success criteria tagged Level A, AA or AAA

If your nonprofit receives HHS financial assistance, the Section 504 rule gives your website a date: May 11, 2027 with 15 or more employees, May 10, 2028 with fewer. The rule does not describe accessibility in its own words. It names a technical standard, WCAG 2.1 at Level A and Level AA, and that standard now comes in several versions and three conformance levels, with a draft successor in circulation. What are the WCAG guidelines, and what does conforming at Level AA ask of your site?

TL;DR

The WCAG guidelines are the W3C’s technical standard for accessible web content, built from four principles, guidelines and testable success criteria at Levels A, AA and AAA, and the HHS Section 504 rule names WCAG 2.1 Level AA. That applies to recipients of HHS financial assistance, the date depends on whether you have 15 or more employees, and the rule lists exceptions and an undue burden limit, so whether they reach your organization is a question for you and your counsel. Conformance is judged per full page and per complete process, so a donation flow counts as one unit and a fix on the homepage does not cover it, and a fix holds only while someone operates the site afterward. For the operating side, compare NoDrama’s WordPress care plans.

What this guide covers

  1. 01Understand the standard
  2. 02Work out what applies to you
  3. 03Plan the work

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.

Verification step

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
Table comparing WCAG versions 2.0, 2.1, 2.2 and the 3.0 draft, with the version the HHS rule names in bold.

What changed between versions:

+17

WCAG 2.1 adds 17 success criteria.

+9

WCAG 2.2 adds 9 success criteria.

4.1.1

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.

How WCAG is structured
Principles at the top, guidelines beneath them, success criteria beneath those
Perceivable
Operable
Understandable
Robust
Guidelines: basic goals under each principle.
Success criteria: testable statements, each rated with a level: A AA AAA
Diagram of the WCAG guidelines structure: four principles, guidelines beneath them, and success criteria tagged Level A, AA or AAA.
Verification step

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
Table showing which success criteria each WCAG conformance level includes.

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

This piece’s own reading

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.

Verification step

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:

May 11, 202715 or more employees
May 10, 2028Fewer than 15 employees
HHS Section 504 web accessibility compliance dates by headcount. Source: 45 CFR 84.84(b).

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.

Verification step

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
Table of the three WCAG 2.2 contrast success criteria, their levels and required ratios.

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.

Verification step

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.

01

Confirm which date is yours.

Verify: the date is in the grant file.

02

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.

03

List full pages and complete processes, donation path first.

Verify: the list exists and each item has an owner.

04

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.

05

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.

See the Three Plans

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.

FAQs

The HHS Section 504 rule, 45 CFR 84.84(b), names Level A and Level AA success criteria and conformance requirements specified in WCAG 2.1. Whether the rule reaches your organization is for you and your counsel.
It applies to recipients of HHS financial assistance, with May 11, 2027 for 15 or more employees and May 10, 2028 for fewer. Whether the exceptions and the undue burden limit reach you is for you and your counsel.
The HHS rule names Level A and Level AA, not Level AAA. The W3C does not recommend requiring Level AAA as a general policy for entire websites.
At Level AA, criterion 1.4.3 asks for at least 4.5:1 for normal text and at least 3:1 for large-scale text.
Not through funding. Section 508 applies to federal agencies, and your obligation comes through Section 504.
Written byPartha Biswas
Written byDeepti KarnHead of Business

Deepti leads business at NoDrama, which she founded in February 2026 after four and a half years at Pangolin Marketing. NoDrama came out of a question she kept running into: who is actually responsible for keeping a WordPress site fast, secure, accessible, and working? She writes about service design, ownership models, and what businesses should expect from whoever maintains their website.

Keep the Site Operated After the Fix

Get Started
Cancel anytime
Yearly runs to the end of the paid year
Real team behind every plan