Questions · The VPAT® and the ACR
Should our ACR report on WCAG 2.1 or WCAG 2.2?
Report at least the version your buyer names. The ADA Title II rule and the HECVAT use WCAG 2.1 AA; Section 508 uses WCAG 2.0. WCAG 2.2 adds six Level A and AA criteria and drops 4.1.1 Parsing, and content that meets 2.2 also meets 2.1. If you can support 2.2, reporting it answers both.
What WCAG 2.2 adds
WCAG 2.2 keeps every WCAG 2.1 criterion except 4.1.1 Parsing, now obsolete, and adds nine: three at Level AAA and the six below. That makes 55 Level A and AA criteria in WCAG 2.2, against 50 in WCAG 2.1.
| Criterion | Level | In short |
|---|---|---|
| 2.4.11 Focus Not Obscured (Minimum) | AA | A component that receives keyboard focus is not entirely hidden by author-created content, such as a sticky banner. |
| 2.5.7 Dragging Movements | AA | Anything operated by dragging can also be done with a single pointer without dragging, unless dragging is essential. |
| 2.5.8 Target Size (Minimum) | AA | Pointer targets are at least 24 by 24 CSS pixels, with exceptions such as sufficient spacing or an equivalent control. |
| 3.2.6 Consistent Help | A | Help mechanisms repeated across pages, such as contact details or a self-help option, keep the same relative order. |
| 3.3.7 Redundant Entry | A | Information already entered in the same process is filled in or available to select, with exceptions such as security. |
| 3.3.8 Accessible Authentication (Minimum) | AA | Signing in doesn’t require a cognitive function test, such as remembering a password, unless an alternative or assistance is provided. |
What each buyer names
- ADA Title II rule: WCAG 2.1 Level A and AA, in its June 5, 2018 version (28 CFR 35.200).
- HECVAT 4.1.6, ITAC-08: “Does the solution substantially conform to WCAG 2.1 AA?” Its guidance adds that a solution substantially conforming to a newer standard such as WCAG 2.2 AA should answer yes.
- Section 508: WCAG 2.0 Level A and AA (36 CFR 1194, E205.4 and E207.2).
- EN 301 549 V4.1.1 (September 2026): web, document and software clauses aligned with WCAG 2.2.
- The W3C: WCAG 2.2 does not supersede 2.1, and “W3C encourages you to use the latest version of WCAG.”
How ACR Desk handles this
We evaluate WCAG 2.1 Level A and AA by default and WCAG 2.2 on request, at the same price: $1,490 for the WCAG edition. Tell us which version your buyer named; the written quote states the version we will report.
Last reviewed: September 30, 2026. Not legal advice: rules change, and your buyer’s solicitation or contract governs what they require.
Sources
Primary sources only. Each was read on September 30, 2026.
- What’s New in WCAG 2.2 — W3C Web Accessibility Initiative.
- Web Content Accessibility Guidelines (WCAG) 2.2 — W3C Recommendation (current version dated December 12, 2024) — W3C.
- Web Content Accessibility Guidelines (WCAG) 2.1 — W3C Recommendation (current version dated May 6, 2025) — W3C.
- WCAG 2 Overview — versions, backwards compatibility, ISO/IEC 40500 and EN 301 549 — W3C Web Accessibility Initiative.
- 28 CFR 35.200 — Requirements for web and mobile accessibility (ADA Title II) — eCFR, current text.
- Higher Education Community Vendor Assessment Toolkit (HECVAT 4, current version 4.1.6) — IT Accessibility questions ITAC-01 to ITAC-18 — EDUCAUSE.
- 36 CFR part 1194, Appendix A — Revised 508 Standards (E205.4, E207.2) and Appendix C (Chapters 3–7) — eCFR, current text.
- EN 301 549 V4.1.1 (2026-09) — Accessibility requirements for ICT products and services — ETSI / CEN / CENELEC.