WCAG 2.1 vs 2.2: choosing a public-sector testing target

The Title II rule names WCAG 2.1 AA

The DOJ Title II web rule references WCAG 2.1 Level AA. A public entity should not silently replace that legal reference with WCAG 2.2 in its compliance plan. State the required standard and any additional organizational target separately.

WCAG is organized by success criteria and conformance levels. Automated rule mappings support evaluation of some criteria; they do not establish complete criterion conformance or full-process conformance. Keep manual evaluation and untested content visible.

What WCAG 2.2 adds

WCAG 2.2 adds criteria addressing problems such as obscured keyboard focus, alternatives to dragging movements, minimum target size, consistent help, redundant entry, and accessible authentication. These are particularly relevant to menus, application forms, and account-based public services.

Not every new criterion is Level AA: the additions span conformance levels. Consult the W3C text for the exact criterion, level, exceptions, and test conditions. Requirements such as minimum target size include specific conditions and exceptions. Consult the full criterion when deciding how it applies to your website.

The Parsing difference matters in a comparison

WCAG 2.2 removes Success Criterion 4.1.1 Parsing. W3C explains the relationship between the versions. When a policy or regulation specifically references 2.1, document that target rather than assuming a 2.2 label alone resolves every requirement.

If results change when a scanner or rule set changes, compare the rule mappings and scope before declaring the website improved or worsened. A removed rule, deduplicated URL, or recommendation reclassification is not evidence of a code repair.

A practical two-layer testing plan

Maintain a required-standard checklist and an additional-usability target. For each criterion, record the evaluation method, representative tasks, evidence, and unresolved questions. New 2.2 work can be planned as a separate column without obscuring the 2.1 AA obligation.

• State the WCAG version and level in procurement and report scope.
• Identify exactly which automated rules ran and which checks could not complete.
• Test focus, dragging alternatives, target interactions, and authentication with real task flows.
• Record human review of criteria that require judgment or interaction.
• Keep retest evidence comparable across tool versions.