What is WCAG 2.2?
The Web Content Accessibility Guidelines (WCAG) are international standards developed by the World Wide Web Consortium (W3C) to ensure that web content is accessible to people with disabilities. The WCAG 2.2 version, finalized on October 5, 2023, builds upon WCAG 2.1 and introduces additional success criteria focusing on users with cognitive disabilities, low vision, and those using mobile devices.
Origin in EU Law: The European Accessibility Act (EAA)
The European Accessibility Act (Directive (EU) 2019/882) was adopted by the European Parliament and Council on 17 April 2019. It aims to harmonize accessibility requirements across the EU and applies to a wide range of products and services, including:
- Websites and mobile apps
- E-books and e-readers
- Banking services
- E-commerce platforms
- Public terminals (e.g., ticket machines)
Member states were required to transpose this directive into national law by 28 June 2022, and the rules will apply from 28 June 2025.
Although the EAA doesn’t explicitly reference WCAG 2.2 (it refers to EN 301 549, which in turn refers to WCAG standards), it effectively enforces the use of WCAG in public digital services.
Implementation in German Law
Germany transposed the EAA into national law through:
1. Barrierefreiheitsstärkungsgesetz (BFSG)
- Enacted: July 2021
- Effective: From 28 June 2025
- Applies to private-sector services and products listed in the EAA
- Based on: Directive (EU) 2019/882
2. Barrierefreie-Informationstechnik-Verordnung (BITV 2.0)
- Original version: 2011
- Update aligning with WCAG 2.1: May 2019
- Currently in the process of alignment with WCAG 2.2
The BITV 2.0 governs public sector websites and mobile applications. It is based on Directive (EU) 2016/2102, which mandates that all public sector bodies must ensure accessibility, referring to EN 301 549, which now includes WCAG 2.2.
Legal and Technical References
| Document | Description | Reference |
|---|---|---|
| Directive (EU) 2016/2102 | Web Accessibility Directive (public sector) | EUR-Lex |
| Directive (EU) 2019/882 | European Accessibility Act (private sector) | EUR-Lex |
| EN 301 549 | Harmonized EU standard including WCAG criteria | ETSI |
| BFSG (2021) | German law for private sector accessibility | BGBl. I 2021, Nr. 35 |
| BITV 2.0 (amended 2019) | German regulation for public sector accessibility | BITV |
The adoption of WCAG 2.2 reflects a stronger focus on cognitive accessibility and mobile usability. While the EU doesn’t legislate WCAG directly, it requires compliance with harmonized standards (EN 301 549), which are based on WCAG. Germany has already laid down the legal groundwork through the BFSG and BITV, and adjustments to align with WCAG 2.2 are expected.
Key Deadlines:
- WCAG 2.2 finalized: October 2023
- EU transposition deadline (EAA): 28 June 2022
- Germany’s private sector compliance (BFSG): 28 June 2025
- BITV update to WCAG 2.2: Expected 2025+
There are accessibility-ready checkers available online, check your pages before the deadline:
