Is Achieving WCAG 2.2 Level AA Sufficient to Comply with European Web Accessibility Regulations?
A11ySolutions
Digital accessibility is an essential component for ensuring the inclusion of all people in the information society. In Europe, this commitment has been solidified through regulations and standards seeking to unify and reinforce accessibility requirements for digital products and services. In this context, a crucial question arises: Is complying with Web Content Accessibility Guidelines (WCAG) 2.2 Level AA sufficient to ensure conformity with the European Accessibility Act (Directive 2019/882) and, consequently, with Spanish regulations?
The EN 301 549 standard, adopted under the EAA, incorporates WCAG but goes further.
Understanding the European Accessibility Act (Directive 2019/882):
Adopted on April 17, 2019, Directive 2019/882 establishes common accessibility requirements for a wide range of products and services in the European Union market. Its goal is to eliminate barriers faced by people with disabilities and facilitate a single market for accessible products and services. Member States were required to transpose this directive into their national legislation by June 28, 2022, and its provisions will be applicable starting June 28, 2025. This rapidly approaching date marks a pivotal milestone for private companies, which must ensure their digital assets comply with the new accessibility standards. The urgency of this deadline requires immediate action by those responsible for digital assets to avoid potential sanctions and guarantee inclusion for all users.
The EN 301 549 Standard: The Harmonized European Standard
The most recent version, EN 301 549 V3.2.1, incorporates WCAG 2.1 Level A and AA criteria. An update to version V4.1.1 is anticipated in 2025, aligning with WCAG 2.2 and other emerging accessibility requirements.
The EN 301 549 standard was initially developed in 2014 by the European Telecommunications Standards Institute (ETSI) in conjunction with CEN and CENELEC to establish functional accessibility requirements for Information and Communication Technology (ICT) products and services in Europe. Subsequently, Directive 2019/882 (European Accessibility Act - EAA), published in 2019, adopted this standard as the technical reference for ensuring digital accessibility in the European Union.
The most recent version, EN 301 549 V3.2.1, incorporates WCAG 2.1 Level A and AA criteria. An update to version V4.1.1 is anticipated in 2025, aligning with WCAG 2.2 and other emerging accessibility requirements. Given that Directive 2019/882 must be implemented by Member States by June 2025, it is critical that companies stay informed about these updates to ensure continuous compliance with European standards.
WCAG 2.2: Update of the Web Accessibility Guidelines
Published as a W3C Recommendation on October 5, 2023, WCAG 2.2 is an update to the international guidelines for web accessibility. This version introduces nine new success criteria designed to better address the needs of users with cognitive and visual disabilities, and those using mobile devices. Although WCAG 2.2 expands and refines previous guidelines, its primary focus is on the accessibility of web content and web applications. However, EN 301 549 encompasses a broader spectrum of accessibility requirements for ICT products and services, meaning WCAG 2.2, while fundamental, does not cover all its aspects.
Is Conformity with WCAG 2.2 Sufficient to Comply with the EAA?
While WCAG 2.2 provides a solid foundation for web accessibility, conformity alone does not guarantee full compliance with the European Accessibility Act (EAA). The EN 301 549 standard, adopted under the EAA, incorporates WCAG but goes further, establishing accessibility requirements for a wider range of ICT products and services, including:
Hardware and software: Specific criteria for physical devices and software applications, ensuring their accessibility for all users, including people with disabilities.
Telecommunications services: Requirements to ensure that electronic communication platforms and services are accessible and usable by people with diverse disabilities.
Electronic documents: Specifications for the accessibility of non-web documents, such as PDFs and other digital formats, which are not directly covered by WCAG.
Compatibility with assistive technologies: Ensures ICT products and services are interoperable with tools like screen readers, alternative input devices, and assistive technologies.
Therefore, to fully comply with the EAA, companies must go beyond web accessibility and evaluate the accessibility of all their digital products and services, ensuring they meet the broader and more detailed requirements of EN 301 549. This implies a comprehensive approach encompassing websites, mobile apps, software, hardware, and digital services in general.
Implementation in Spain: Royal Decree 193/2023
*28 June 2025: Date on which Law 11/2023 comes into force, becoming mandatory in Spain and the rest of European countries. From this date, new products and services must be accessible.*
In Spain, the transposition of Directive (EU) 2019/882 has been carried out through Law 11/2023, of May 8th, which regulates accessibility requirements for specific products and services. This law extends accessibility obligations to the private sector, specifying that all websites and mobile applications offering goods and services to the public must comply with the accessibility criteria established in the UNE-EN 301 549 standard.
Furthermore, the following deadlines are established for implementing these measures:
28 June 2025: Date on which Law 11/2023 comes into force, becoming mandatory in Spain and the rest of European countries. From this date, new products and services must be accessible.
28 June 2030: Service providers may continue using products already in use before June 28, 2025, until this date, provided no substantial modifications are made to said products.
Given that June 28, 2025, is imminent and that an adaptation project can take several months depending on the complexity of a company's digital assets, it is crucial that private companies, especially those interacting with the public sector, prioritize adapting their digital assets to comply with established accessibility standards. Inaction could result in sanctions and, more importantly, the exclusion of a significant portion of the population.
How Can A11YSolutions Help Your SME?
Accessibility Audits:
At A11ySolutions, we understand that a comprehensive accessibility audit is crucial to ensure that your website and applications not only comply with current regulations but also offer an optimal user experience for everyone. Our Audits combine meticulous manual evaluations with advanced automated testing to deliver an in-depth and comprehensive analysis of your digital assets' accessibility.
Integrated Approach and Technologies Used:
Automated Tools:
Advanced automation tools are used to optimize the detection of accessibility issues. These tools are essential for identifying deficiencies in colour contrast, a critical task on pages with dense visual elements. Furthermore, they facilitate the evaluation of heading structure, lists, and other similar components, which is indispensable for users relying on screen readers. The review of structural logic and sequence is efficiently performed using these technologies.
They also verify the correct implementation of ARIA attributes, whose complexity and variability make them especially difficult to evaluate manually. This approach not only increases accuracy in meeting accessibility standards but also ensures a consistent and accessible user experience for all.
Manual Evaluations:
We complement automated testing with manual evaluations, where our experts use a variety of assistive technologies and navigation techniques to simulate the experience of users with diverse disabilities. This includes:
Screen readers: Software like JAWS, NVDA, and VoiceOver are used to ensure content is fully accessible and navigable without needing to see the screen.
Keyboard navigation: We verify that all website functions can be operated using the keyboard exclusively, a necessity for many users with motor disabilities.
Colour Contrast Tests: We perform additional manual checks to identify issues not captured by automated tools, especially in dynamic contexts or with multimedia content.
Form Validation: We ensure all forms are accessible, including clear labels, accessible error messages, and adequate instructions.
Use of Mobile Technology: We extend testing to mobile devices, using native screen readers and specific accessibility gestures for tablets and smartphones.
Testing of Captions and Transcripts for Media: We verify the presence and accuracy of captions for videos and audios, including audio descriptions and transcripts.
Semantic Navigation Assessment: We review semantic roles and landmark roles to ensure a logical and understandable page structure via screen readers.
User Experience Testing in Low Vision Situations: We use low vision simulators and evaluate zoom functionality and text customization.
Interoperability with Various Browsers and Screen Readers: We ensure the site works correctly across a wide variety of browser and screen reader combinations.
These practices allow us to have a more holistic and detailed view of the website's accessibility, ensuring that the needs of all users are met, regardless of their abilities.
Audit Process:
Pre-Audit: Collection of information on the client's accessibility goals and preparation of the test environment.
Audit Execution: Performance of automated and manual tests, using the aforementioned technologies for comprehensive analysis.
Findings Report: Detailed documentation of all accessibility issues found, accompanied by screenshots, problem descriptions, and references to the violated WCAG success criteria.
Recommendations and Solutions: We provide practical solutions and guidance on how to resolve identified issues, including code changes, design adjustments, and best practices for future maintenance.
Commitment to Excellence: Our comprehensive approach ensures that we not only identify problems but also provide the most effective and up-to-date solutions, guaranteeing that your website and applications are fully accessible and prepared to meet current and future standards. With A11ySolutions Audits, your organization can expect not only to comply with laws and regulations but also to lead in digital inclusion and web accessibility.
Implementation and Remediation Services:
Development of Corrective Actions: We offer complete code remediation services as part of our commitment to accessibility. After identifying accessibility issues in our audits, we are prepared to implement the fixes directly on your website if you wish. This service goes beyond merely identifying problems, providing technical implementations that rectify the detected accessibility barriers.
Integration with Existing Teams: We understand the importance of seamless integration with your current processes and teams. Therefore, our developers can work side-by-side with your internal team, providing guidance and technical support to ensure all accessibility improvements are implemented efficiently and in line with industry best practices.
Collaboration with Design Teams: We work hand-in-hand with your design team from the earliest stages of product development, reviewing and advising on mockups and wireframes to ensure all components and functionalities are designed with accessibility in mind. This proactive approach prevents accessibility issues before they occur and ensures a more natural and effective integration of accessibility.
Testing and Continuous Validation: Once solutions are implemented, we conduct a full cycle of testing to verify everything works as expected and accessibility standards are maintained.
Accessible Documentation
We ensure all your documentation, including PDF files, Word documents, presentations, and spreadsheets, is fully accessible. This service guarantees that documents are as easy to read for users with low or no vision as they are for those without visual disabilities, meeting accessibility standards and offering a uniform and equitable user experience.
Commitment to Universal Accessibility: Our goal is to eliminate digital barriers and enrich the user experience for everyone. By delegating the implementation of accessibility fixes to A11ySolutions, you not only guarantee regulatory compliance but also improve usability and end-user satisfaction. We are dedicated to ensuring your digital presence is accessible, inclusive, and successful.
Documentation and Conformity
VPAT (Voluntary Product Accessibility Template): We will develop and update your VPAT to clearly document your digital product's conformity with WCAG accessibility standards, identifying any potential barriers users might encounter.
Accessibility Statements
Drafting of Accessibility Statements: We will draft and publish accessibility statements reflecting your commitment to inclusion and regulatory compliance. This not only improves transparency towards your users but also strengthens your company's trust and corporate image.
Benefits of Working with A11ySolutions
Legal Compliance and Improved Corporate Image: We ensure your company complies with all applicable web accessibility laws, improving your corporate image and avoiding sanctions.
Cost Reduction and Continuous Improvement: Through proper implementation from the start, we reduce long-term costs and help your company continuously adapt to legislative changes and new technical standards.
With A11YSolutions, you will not only avoid the most common mistakes but also improve your users' experience and strengthen your company's reputation as an entity committed to inclusion.
What to Do?
While WCAG 2.2 is fundamental for ensuring web content accessibility, it is not sufficient by itself to ensure compliance with the European Accessibility Act and the Spanish regulations derived from it. The EN 301 549 standard offers a more comprehensive framework covering a variety of ICT products and services, including hardware, software, and telecommunications services. Therefore, organizations operating in Spain and the rest of the European Union must ensure they comply with the requirements established in EN 301 549 and the specific provisions of Royal Decree 193/2023 to guarantee full accessibility and avoid potential sanctions.