WCAG 2.2 Website Audit: Test AA Conformance

A WCAG website audit tests a defined set of pages, states and complete processes against every applicable success criterion at the claimed level. Record the WCAG version, conformance target, technologies relied upon, test methods and known limitations.

WCAG 2.2 is the current W3C Recommendation and adds nine criteria to WCAG 2.1 while removing 4.1.1 Parsing. A law or contract may still incorporate WCAG 2.0 or 2.1, so identify that boundary before testing.

WCAG Structure Explained

WCAG is organised into a clear hierarchy. Understanding this structure is essential for navigating the standard and conducting a systematic audit.

Four principles: At the highest level, WCAG is built on four principles known by the acronym POUR. Perceivable means users must be able to perceive the information presented. Operable means users must be able to operate the interface. Understandable means users must be able to understand the information and the operation of the interface. Robust means content must be robust enough to be interpreted by a wide range of user agents, including assistive technologies.

Thirteen guidelines: Under the four principles sit thirteen guidelines that provide the framework for each area of accessibility. For example, under the Perceivable principle, Guideline 1.1 addresses text alternatives, Guideline 1.2 addresses time-based media, Guideline 1.3 addresses adaptable content, and Guideline 1.4 addresses distinguishable content. Guidelines are not testable themselves — they provide the context for the success criteria beneath them.

Success criteria: Each guideline contains testable requirements at Level A, AA or AAA. WCAG 2.2 contains 86 success criteria after 4.1.1 Parsing was removed. Use the normative standard rather than relying on a remembered count.

Three conformance levels: Level A contains the baseline criteria, Level AA includes every applicable Level A and AA criterion, and Level AAA includes all three levels. Legal and contractual targets vary: for example, the US Department of Justice's Title II web rule names WCAG 2.1 Level AA, while W3C recommends using WCAG 2.2 for current work.

Conformance at a given level requires meeting all criteria at that level and below for full pages and complete processes. A sample audit can identify defects but cannot establish whole-site conformance outside its scope.

Level A Requirements

Level A criteria address the most basic and fundamental accessibility needs. Failure at this level typically means content is completely inaccessible to one or more disability groups. Every website, regardless of its target conformance level, must meet all Level A criteria.

The most impactful Level A criteria include:

• 1.1.1 Non-text Content — all non-text content (images, icons, charts, CAPTCHA) must have a text alternative that serves the same purpose. This is the foundation of accessibility for screen reader users. Informational images need descriptive alt text. Decorative images need empty alt attributes. Complex images like charts need longer descriptions.
• 1.3.1 Info and Relationships — information, structure, and relationships conveyed through presentation must be programmatically determinable or available in text. Headings must use heading elements (h1-h6), not just bold text. Lists must use list elements. Tables must have header cells. Form fields must have programmatically associated labels.
• 2.1.1 Keyboard — all functionality must be operable through a keyboard interface without requiring specific timings for individual keystrokes. This is critical because many assistive technologies emulate keyboard input.
• 2.1.2 No Keyboard Trap — if keyboard focus can be moved to a component, focus can be moved away from that component using only a keyboard. Keyboard traps are one of the most severe accessibility barriers because they physically prevent users from navigating further.
• 4.1.1 Parsing — in content implemented using markup languages, elements have complete start and end tags, elements are nested according to their specifications, elements do not contain duplicate attributes, and IDs are unique. Note that WCAG 2.2 marks this criterion as always satisfied for HTML, but it remains relevant for WCAG 2.1 audits.
• 4.1.2 Name, Role, Value — for all user interface components, the name and role must be programmatically determinable, states and properties must be set correctly, and changes to these must be available to user agents including assistive technologies. This is the criterion that governs ARIA implementation on custom widgets.

Level A also includes alternatives for prerecorded audio-only and video-only media (1.2.1), captions for prerecorded synchronised media (1.2.2), audio description or a media alternative (1.2.3), meaningful sequence (1.3.2), sensory characteristics (1.3.3), use of colour (1.4.1), audio control (1.4.2), timing adjustability (2.2.1), pause/stop/hide (2.2.2), three flashes threshold (2.3.1), bypass blocks (2.4.1), page titles (2.4.2), focus order (2.4.3), link purpose in context (2.4.4), page language (3.1.1), predictable focus and input behaviour (3.2.1 and 3.2.2), error identification (3.3.1), and labels or instructions (3.3.2).

Level AA Requirements

Level AA adds criteria concerning contrast, reflow, navigation, input and other barriers. Test the criteria listed for the selected WCAG version rather than carrying a WCAG 2.1 count into a WCAG 2.2 audit.

Key Level AA criteria include:

• 1.4.3 Contrast (Minimum) — text and images of text must have a contrast ratio of at least 4.5:1, with the exception of large text (18pt or 14pt bold and above) which requires 3:1. This is one of the most frequently failed criteria because designers often prioritise aesthetic colour choices over contrast ratios.
• 1.4.4 Resize Text — text can be resized up to 200 percent without assistive technology and without loss of content or functionality. This primarily tests whether your site handles browser zoom gracefully without text overlapping, getting cut off, or disappearing.
• 1.4.10 Reflow — content can be presented without horizontal scrolling at a width of 320 CSS pixels (equivalent to 400% zoom on a standard 1280px viewport). This WCAG 2.1 criterion ensures responsive design works for users who need extreme magnification.
• 1.4.11 Non-text Contrast — user interface components and graphical objects required to understand content must have a contrast ratio of at least 3:1 against adjacent colours. This includes form field borders, icons, chart elements, and focus indicators.
• 2.4.6 Headings and Labels — headings and labels must describe the topic or purpose of the content they introduce. Headings like "Section 1" and labels like "Field 1" fail this criterion because they do not communicate meaning.
• 2.4.7 Focus Visible — any keyboard-operable user interface must have a mode of operation where the keyboard focus indicator is visible. Removing the default browser focus outline with CSS (outline: none) without providing a replacement violates this criterion.
• 3.3.3 Error Suggestion — if an input error is detected and suggestions for correction are known, the suggestions must be provided to the user, unless doing so would jeopardise security or purpose. For example, if a user enters an invalid email format, the error message should explain what a valid format looks like.
• 3.3.4 Error Prevention (Legal, Financial, Data) — for pages that cause legal commitments, financial transactions, or data modifications, at least one of the following is true: submissions are reversible, data is checked and the user has an opportunity to correct errors, or a mechanism is available for reviewing and confirming before final submission.

Other Level AA criteria cover captions for live audio (1.2.4), audio description for pre-recorded video (1.2.5), multiple navigation mechanisms (2.4.5), language of parts (3.1.2), consistent navigation (3.2.3), consistent identification (3.2.4), and WCAG 2.1 additions including orientation independence (1.3.4), input purpose identification for autocomplete (1.3.5), text spacing override support (1.4.12), content on hover or focus accessibility (1.4.13), character key shortcuts (2.1.4), pointer cancellation (2.5.2), label in name for speech input (2.5.3), motion actuation alternatives (2.5.4), and status messages announced by live regions (4.1.3).

Level AAA Optional

Level AAA represents the highest standard of accessibility. It is not typically required as a blanket target because some criteria are extremely difficult to meet for all types of content. For example, criterion 1.4.6 requires a contrast ratio of 7:1 for normal text, which severely limits colour palette options. Criterion 1.2.6 requires sign language interpretation for all pre-recorded audio, which is costly and impractical for most organisations.

However, many Level AAA criteria are achievable and worth pursuing even if you are targeting AA conformance:

• 2.4.9 Link Purpose (Link Only) — the purpose of each link can be identified from the link text alone, without needing the surrounding context. This is a stricter version of the Level A criterion (2.4.4) which allows link purpose to be determined from the link plus its surrounding context.
• 3.1.3 Unusual Words — a mechanism is available to identify specific definitions of words used in an unusual or restricted way, including idioms and jargon. Glossaries and tooltip definitions satisfy this criterion.
• 3.1.5 Reading Level — when text requires more than a lower secondary education reading level, a supplemental version is available that does not require more than that level. This criterion promotes plain language, which benefits all users.
• 2.2.3 No Timing — timing is not an essential part of any event or activity, except for real-time events. This is achievable for most website content and improves the experience for users who need more time to process information.
• 1.4.8 Visual Presentation — for blocks of text, users can select foreground and background colours, width is no more than 80 characters, text is not justified, line spacing is at least 1.5 within paragraphs, and text can be resized up to 200% without horizontal scrolling. These are good typographic practices that benefit readability for everyone.

In an audit context, we test and report on Level AAA criteria as advisory findings — improvements that would enhance accessibility beyond the AA baseline but are not counted against conformance. Organisations that serve audiences with higher accessibility needs (government services, healthcare, education) should consider AAA criteria more seriously.

Testing Each Criterion

A WCAG audit involves testing every applicable success criterion on every unique page template and interactive component in your site. Here is a practical approach to structuring the testing process.

Create a test matrix. List the applicable success criteria in rows and representative pages, components, states and complete processes in columns. Record pass, fail, not present or not tested with evidence. Reserve VPAT support terms for an Accessibility Conformance Report.

Group criteria by testing method. Some criteria can be tested with automated tools. Others require keyboard testing. Others require screen reader testing. Others require visual inspection. Group your testing by method to avoid switching contexts constantly. Run all automated tests first, then do all keyboard testing, then all screen reader testing, then all visual checks.

Automated testing contributes evidence for: 1.1.1 (whether an alt attribute exists, not whether its text is appropriate), parts of 1.3.1, some contrast cases, 2.4.2 and 3.1.1. Tool rules, coverage and confidence differ, and a passing scan is not a WCAG conformance result. Validate findings and test the remaining criteria manually.

Keyboard testing covers: 2.1.1 (keyboard operability), 2.1.2 (no keyboard trap), 2.4.3 (focus order), 2.4.7 (focus visible), 3.2.1 (focus behaviour). Tab through every interactive element on each page template and document any failures.

Screen reader testing covers: 1.1.1 (alt text quality), 1.3.1 (semantic structure perception), 4.1.2 (name, role, value), 4.1.3 (status messages), 2.4.4 and 2.4.6 (link purpose and heading/label quality), and others. Navigate with NVDA or VoiceOver and evaluate whether the experience is coherent and complete.

Visual testing covers: 1.4.1 (use of colour), 1.4.3 (contrast), 1.4.4 (resize to 200%), 1.4.10 (reflow at 320px), 1.4.12 (text spacing), 2.3.1 (flashing content), and others. These criteria require human eyes to evaluate.

For each failure found, document the criterion violated, the specific element and page, a description of the problem, the impact on users, and a remediation recommendation. Take screenshots or record video evidence where possible — this documentation is essential for the conformance report and for communicating issues to the development team.

Conformance Statement

A WCAG conformance claim is optional and must include the items W3C specifies, including the date, guideline version, conformance level, pages covered and technologies relied upon. An Accessibility Conformance Report (ACR) is a separate product report, often created from a VPAT template, that procurement teams may request.

The Information Technology Industry Council publishes the Voluntary Product Accessibility Template (VPAT). An organisation can use the appropriate edition to prepare an ACR covering WCAG, US Section 508, European EN 301 549 or more than one of those standards. Follow the current template instructions rather than copying an old report.

For each success criterion, the conformance statement includes a conformance level indicator using one of these standardised terms:

• Supports — the functionality of the product has at least one method that meets the criterion without known defects or meets with equivalent facilitation.
• Partially Supports — some functionality of the product does not meet the criterion.
• Does Not Support — the majority of product functionality does not meet the criterion.
• Not Applicable — the criterion is not relevant to the product. For example, a site with no video content can mark video-related criteria as not applicable.

Each entry also includes a "Remarks and Explanations" column where you describe what works, what does not work, and what your plans are for remediation. This column is where the practical detail lives and where reviewers spend most of their time.

Base each reported term on the tested product and explain exceptions in the remarks. Do not turn a sampled website review into a claim about untested pages, states, documents or third-party content.

Review a claim or ACR after material product changes, remediation or a change in the required standard. State its date and scope so readers can judge whether it still represents the current product.

Use the normative WCAG 2.2 Recommendation, W3C's WCAG-EM evaluation method and the current VPAT instructions. The practical checklist helps with initial defect discovery.