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WCAG 2.1 vs 2.2

WCAG 2.2 adds nine new success criteria on top of 2.1 — covering areas like focus appearance, dragging alternatives, and consistent help — but EN 301 549, the standard most European accessibility regulation currently references, is still built around WCAG 2.1 AA, so that remains the applicable target unless your specific compliance requirement states otherwise.

In detail

What actually changed, and which one applies to you

What 2.2 adds

WCAG 2.2, published in 2023, adds new success criteria addressing gaps identified since 2.1, including clearer focus indicators, alternatives to drag interactions, and more consistent help mechanisms across a site — refinements rather than a wholesale change in approach.

Why 2.1 is still the practical target

EN 301 549, the reference standard most current European accessibility regulation including the EAA points to, is built around WCAG 2.1 AA. Building to that specific target is what satisfies the applicable legal requirement today, even though 2.2 is the more current technical version.

What we actually recommend

Build to WCAG 2.1 AA as the compliance baseline, and adopt the additional 2.2 criteria where reasonably practical, since they represent genuine usability improvements even where not strictly required. See accessibility compliance for how we scope that in practice.

Related questions

Will EN 301 549 be updated to reference 2.2?

Accessibility standards do get revised on a rolling cycle, and EN 301 549 will likely reference WCAG 2.2 or a later version at some point. We build to the version currently in force rather than anticipating one that has not yet been formally adopted, since that keeps cost and scope tied to an actual legal requirement. Confirm the current reference with your legal or regulatory team.

What is EN 301 549 exactly?

EN 301 549 is the European accessibility standard that public and many private-sector digital services must meet, and it works by referencing a specific version of WCAG rather than defining its own separate rules. For pharma websites in the EU, it is usually the practical route through which WCAG compliance becomes a legal requirement. See what is EN 301 549 for the fuller explanation.

Does the EAA require 2.1 or 2.2?

The European Accessibility Act does not name a WCAG version directly — it points to EN 301 549, which currently references WCAG 2.1 at level AA. That makes 2.1 AA the operative bar for compliance today, even though 2.2 already exists as a published standard. See does the EAA apply to pharma websites for scope details.

What's different between WCAG 2.1 and 2.2 for a pharma site?

WCAG 2.2 adds nine success criteria on top of 2.1, mostly around focus visibility, target size, and authentication flows — areas that affect HCP and patient portal logins more than general marketing pages. Building to 2.2 now is not required under current EU rules, but it is a reasonable target for any new portal build, since it reduces rework later. Confirm scope with legal review.

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