Web Accessibility in 2026: WCAG 2.2, ADA Compliance, and the Business Case for Inclusive Design

Web accessibility has evolved from a niche concern to a fundamental business requirement. With approximately 1.3 billion people worldwide living with significant disabilities-representing 16% of the global population-designing websites that exclude this audience isn't just ethically problematic; it's financially irrational.¹ As legal requirements tighten and consumer expectations rise, understanding accessibility standards has become essential for every business with a digital presence.

The numbers are stark: web accessibility lawsuits in the United States reached a record 4,605 federal filings in 2025, representing a 23% increase from the previous year.² Settlement amounts have also increased, with average resolution costs now exceeding $50,000 for small businesses and reaching millions for large enterprises. Beyond litigation risk, inaccessible websites simply perform worse-they exclude potential customers, harm SEO performance, and damage brand reputation.

Understanding WCAG 2.2

The Web Content Accessibility Guidelines (WCAG) 2.2, published by the World Wide Web Consortium (W3C) in October 2023, represent the current international standard for web accessibility.³ Building on the foundation of WCAG 2.1, the updated guidelines introduce nine new success criteria specifically addressing the needs of users with cognitive disabilities, users with low vision, and users of mobile devices.

WCAG organizes its guidelines around four principles, often abbreviated as POUR: content must be Perceivable, Operable, Understandable, and Robust. Each principle contains specific guidelines, and each guideline has testable success criteria at three conformance levels: A (minimum), AA (recommended), and AAA (enhanced).⁴

Key WCAG 2.2 Additions

Focus Not Obscured (Minimum) - Level AA: When a user interface component receives keyboard focus, the component must not be entirely hidden by author-created content. This addresses the common frustration of tabbing through a page and having the focus indicator disappear behind sticky headers or modal overlays.⁵

Dragging Movements - Level AA: Any functionality that uses dragging can be achieved through a single pointer without dragging. This benefits users who cannot perform drag operations due to motor impairments or who use assistive technologies incompatible with drag-and-drop interfaces.⁶

Target Size (Minimum) - Level AA: Interactive targets must be at least 24 by 24 CSS pixels, with some exceptions. This criterion directly addresses the difficulty many users experience with small touch targets, particularly on mobile devices.⁷

Consistent Help - Level A: If a website provides help mechanisms, those mechanisms must appear in the same relative order across multiple pages. This supports users with cognitive disabilities who rely on consistent patterns to navigate websites.⁸

Redundant Entry - Level A: Information previously entered by or provided to the user that is required to be entered again in the same process must be auto-populated or available for selection. This reduces cognitive load and minimizes errors for all users.⁹

The Legal Landscape in 2026

The legal framework for web accessibility continues to evolve, with significant developments in both legislation and case law. In the United States, the Americans with Disabilities Act (ADA) remains the primary federal law governing accessibility, though it doesn't explicitly mention websites. Courts have increasingly interpreted the ADA's "places of public accommodation" to include websites, particularly for businesses with physical locations.¹⁰

Department of Justice Regulations

The Department of Justice's 2024 rulemaking under Title II of the ADA established explicit web accessibility requirements for state and local government entities, requiring WCAG 2.1 Level AA compliance.¹¹ While Title II applies only to government entities, the rulemaking signals the DOJ's interpretation of accessibility standards and has influenced private litigation.

The DOJ has indicated it is considering similar rulemaking for Title III, which covers private businesses. Legal experts anticipate formal regulations within the next two to three years, though the political environment could affect the timeline.¹²

State-Level Requirements

Several states have enacted accessibility requirements more stringent than federal standards. California's Unruh Civil Rights Act has been particularly significant, allowing for statutory damages of $4,000 per violation-and courts have interpreted each inaccessible page element as a separate violation.¹³

New York, Colorado, and Illinois have also strengthened accessibility requirements, creating a patchwork of state regulations that businesses must navigate. For companies operating nationally, compliance with the most stringent requirements effectively becomes the baseline standard.¹⁴

European and International Requirements

The European Accessibility Act (EAA), which came into full effect in June 2025, mandates accessibility for a wide range of products and services sold in the European Union, including websites and mobile applications of businesses above certain size thresholds.¹⁵ The EAA references the EN 301 549 standard, which incorporates WCAG 2.1 Level AA.

For businesses operating internationally, the convergence around WCAG 2.1/2.2 Level AA as the de facto standard simplifies compliance planning, even as specific enforcement mechanisms vary by jurisdiction.

Common Accessibility Barriers

Understanding the most prevalent accessibility issues helps prioritize remediation efforts. Research from WebAIM, which conducts annual analyses of the top million home pages, identifies several recurring problems.¹⁶

Low Contrast Text

Insufficient color contrast remains the most common accessibility error, appearing on 83% of analyzed home pages. WCAG requires a minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text (18pt or 14pt bold).¹⁷ Light gray text on white backgrounds, a popular design choice, typically fails these requirements.

Tools like WebAIM's Contrast Checker or browser developer tools can identify contrast issues. The fix is straightforward-darken text or lighten backgrounds-though it may require design system updates to implement consistently.

Missing Alternative Text

Images without alternative text (alt text) prevent screen reader users from understanding visual content. WebAIM found that 54% of home page images lacked appropriate alternative text.¹⁸ Effective alt text is concise, describes the image's content or function, and avoids phrases like "image of" which are redundant when screen readers already announce the element as an image.

Decorative images that don't convey meaning should have empty alt attributes (alt="") so screen readers skip them entirely. Informative images should have alt text that conveys the same information a sighted user would gain from the image.

Empty Links and Buttons

Links and buttons without discernible text create significant barriers for screen reader users, who hear only "link" or "button" without any indication of purpose. This often occurs with icon-only buttons or links wrapped around images without alt text.¹⁹

Solutions include adding visible text, providing alt text for image links, or using aria-label attributes to provide screen reader-accessible names for interactive elements.

Missing Form Labels

Form inputs without properly associated labels make forms difficult or impossible to complete for screen reader users. The connection between labels and inputs must be explicit-either through the label element's "for" attribute matching the input's "id," or by nesting the input within the label element.²⁰

Placeholder text is not a substitute for labels. Placeholders disappear when users begin typing, leaving no indication of what information is expected. Proper labels benefit all users, not just those using assistive technology.

Keyboard Navigation Issues

Many websites cannot be fully operated using only a keyboard, excluding users who cannot use a mouse due to motor impairments, vision impairments, or other disabilities. Common issues include: missing focus indicators, focus traps in modal dialogs, and interactive elements that don't receive keyboard focus.²¹

Testing keyboard accessibility requires manually tabbing through every page and ensuring all interactive elements can be reached, activated, and escaped using only the keyboard.

The Business Case for Accessibility

Beyond legal compliance, accessibility delivers measurable business benefits. The Disability:IN annual report estimates that the disability market represents over $8 trillion in global disposable income, with friends and family of disabled individuals representing an additional $15 trillion in spending influence.²²

SEO Benefits

Many accessibility practices directly improve search engine optimization. Alternative text for images, proper heading hierarchy, descriptive link text, and semantic HTML all help search engines understand page content. Research from Search Engine Journal indicates that websites meeting WCAG AA standards typically outperform non-compliant competitors in organic search visibility.²³

Improved User Experience for Everyone

Accessible design benefits all users, not just those with permanent disabilities. Situational disabilities-using a phone in bright sunlight, watching video in a quiet environment, navigating a website while holding a child-affect nearly everyone at some point. Features like captions, high contrast modes, and large touch targets improve usability across contexts.²⁴

Microsoft's inclusive design research demonstrates that designing for permanent disabilities creates solutions applicable to much larger populations. Captions designed for deaf users benefit the 8% of Americans who are deaf or hard of hearing, plus the much larger population who watch video without sound.²⁵

Conversion Rate Improvements

Accessible websites typically convert better because they're easier to use. Click-Tale's analysis of e-commerce sites found that accessibility improvements correlated with 15-20% increases in conversion rates, likely because accessible design principles-clear navigation, readable text, obvious interactive elements-benefit all users.²⁶

Implementation Strategies

For organizations beginning accessibility efforts, a phased approach typically works best. Complete remediation of large websites can take months or years; prioritizing high-impact issues on high-traffic pages delivers faster results.²⁷

Automated Testing

Automated accessibility tools can identify many common issues quickly. Tools like axe DevTools, WAVE, and Lighthouse accessibility audits scan pages for technical violations like missing alt text, insufficient contrast, and missing form labels. However, research from the Government Digital Service indicates that automated tools can only detect approximately 30-40% of accessibility issues; manual testing remains essential.²⁸

Manual Testing and User Research

Manual testing with assistive technologies-screen readers, keyboard-only navigation, screen magnification-reveals issues automated tools miss. Testing should include: full keyboard navigation of all functionality, screen reader testing with at least VoiceOver (Mac/iOS) and NVDA or JAWS (Windows), and zoom testing at 200% and 400% magnification.²⁹

User testing with people with disabilities provides insights that technical testing cannot. Organizations serious about accessibility should include disabled users in their regular usability testing programs.

Accessibility Statements and Feedback Mechanisms

An accessibility statement communicates your commitment to accessibility, discloses known limitations, and provides contact information for users encountering barriers. Under the EAA and various other regulations, accessibility statements are legally required for covered entities.³⁰

Beyond legal requirements, feedback mechanisms allow users to report issues you've missed. Responding promptly to accessibility complaints demonstrates good faith and can help avoid litigation.

Conclusion

Web accessibility in 2026 is no longer optional-it's a legal, ethical, and business imperative. The standards are clear (WCAG 2.2 Level AA), the legal risks are real and growing, and the business benefits are well-documented. Organizations that proactively embrace accessibility will avoid costly litigation, reach larger audiences, and build more usable websites for everyone.

The path to accessibility doesn't require perfection immediately. Start with an audit to understand current gaps, prioritize high-impact fixes, build accessibility into development processes, and continuously improve. Every step toward accessibility is a step toward a more inclusive digital world-and a better performing website.