The Web Content Accessibility Guidelines (WCAG) are intended to ensure that web content developers have a benchmark to use when creating accessible digital content like websites and cookie banners. The latest version, WCAG 2.2, was published in October 2023. As 16% of the world’s population – around 1 in 6 people – live with a disability, making the web more accessible has become essential.
The European Accessibility Act 2025, due to come into full effect on 28 June 2025, will add to the pressure for a more inclusive online environment. As an integral part of the user experience, cookie banners must also comply with these guidelines. Compliance with WCAG 2.2 not only improves accessibility, but also helps to mitigate legal and reputational risks. In this article, we’ll take a closer look at WCAG 2.2, discuss how it differs from WCAG 2.1, explain why it is important for cookie banners to comply, and offer practical steps on how to implement these changes.
❗Important: Our new Accessibility Widget will soon be available to help people with disabilities navigate your website more easily. Keep an eye on your inbox for our next update! 📧
Understanding WCAG 2.2
The WCAG (Web Content Accessibility Guidelines) are a set of guidelines recognized internationally, to ensure web content is accessible to people with disabilities. These guidelines apply to all kinds of devices, including desktops, laptops, kiosks, and mobile devices. The aim is to make the digital world more inclusive by addressing the needs of users with various disabilities, such as blindness, low vision, deafness, hearing loss, limited movement, speech disabilities, and photosensitivity.
The 13 guidelines in WCAG 2.2 are built on four key principles—Perceivable, Operable, Understandable, and Robust (the POUR model). Each guideline includes a set of success criteria categorized into three conformance levels: A, AA, and AAA, with AAA representing the highest level of accessibility. Additionally, the working group has provided “Sufficient and Advisory Techniques” beneath these guidelines and success criteria to help website owners or developers implement solutions that meet diverse user needs.
WCAG 2.1 vs. WCAG 2.2
The aim of WCAG 2.2 was to build on WCAG 2.1 and focus on improving the guidance for making digital content more accessible for 3 main groups:
- Users with cognitive and learning disabilities
- Users with low vision
- Users with disabilities on mobile devices
Specifically, the new criteria mentioned in the new WCAG 2.2 guidelines are:
- 2.4.11 Focus Not Obscured (Minimum) (AA)
- 2.4.12 Focus Not Obscured (Enhanced) (AAA)
- 2.4.13 Focus Appearance (AAA)
- 2.5.7 Dragging Movements (AA)
- 2.5.8 Target Size (Minimum) (AA)
- 3.2.6 Consistent Help (A)
- 3.3.7 Redundant Entry (A)
- 3.3.8 Accessible Authentication (Minimum) (AA)
- 3.3.9 Accessible Authentication (Enhanced) (AAA)
Click here to find the official publication of whats new in the WCAG 2.2 guidelines.
Following the WCAG guidelines can help ensure compliance with the upcoming European Accessibility Act (EAA).
To ensure compliance with WCAG 2.1 or WCAG 2.2, we recommend that you:
- test your website, app or cookie banner with web accessibility evaluation tools or
- if you’re using a Consent Management Platform (CMP) such as consentmanager, follow these step-by-step instructions to enable accessibility features directly on your cookie banner: https://help.consentmanager.net/books/cmp/page/working-with-accessibility-wcag
📣 Attention: Our Accessibility Scanner is launching soon – with this tool you can have your website audited in real time and receive a detailed report on how accessible it is according to the guidelines. Watch this space!
How does WCAG 2.2 Compliance in Cookie Banners look like?
When we refer to WCAG compliance for cookie banners, we are talking about ensuring that cookie consent banners follow the accessibility guidelines set forth in WCAG 2.2.
An example of this can be seen in the above new WCAG 2.2 criterion, Focus Not Obscured. When a user navigates your site using a keyboard (e.g. pressing the arrow keys to move between buttons or links, or scrolling through the page), does your cookie banner remain visible without blocking the content?
An accessible cookie banner should not block important focus points. A “focus point” refers to the element the user has selected or is interacting with on the page, highlighted by keyboard navigation.
To meet WCAG 2.2 standards, your cookie banner should follow the POUR principles:
- Perceivable: Ensure that the banner can be seen, heard or perceived in a way that is easy to undestand. For example, a minimum color contrast should be met of 4.5:1.
- Operable: Allow users to navigate the cookie banner and make selections using only the keyboard, ensuring accessibility for those who cannot use a mouse.
- Understandable: Ensure that the text and any buttons on your cookie banner are clear and easy to understand.
- Robust: Ensure that the cookie banner works consistently across platforms, whether through web browsers or assistive technologies such as screen readers.
For some graphic examples of the do’s and don’ts of cookie banner compliance with the WCAG guidelines, see our article here: https://www.consentmanager.net/en/knowledge/eaa-2025/
Why should my cookie banner be WCAG 2.2 compliant?
Increase user confidence and engagement with accessible cookie banners
Cookie banners adapted for accessibility greatly improve the overall online experience for users with disabilities and builds confidence in your business processes by demonstrating your proactive adherence to industry standards and commitment to inclusivity. With the world’s population rapidly aging, the UN Department of Economic and Social Affairs predicts that by 2050 the number of people aged 60 and over will almost reach 22% of the world’s population, up from 12% in 2015. Given these statistics, the demand for accessible cookie banners will only continue to grow.
Legal and Reputational Risks of Non-Compliance
With the European Accessibility Act (EAA) set to take effect in 2025, your cookie banner should adhere to accessibility standards before this takes place. Once the deadline passes, authorities are expected to begin audits and issue fines—much like what we observed with the enforcement of the GDPR, where fines affected businesses across all sectors. In addition to legal consequences, non-compliance can harm your reputation; inaccessible cookie banners, for instance, may alienate potential customers, particularly those with disabilities.
If you’re a web or app developer, UX/UI designer or product manager, understanding these statistics and keeping track of regulatory deadlines will help support the success of your digital content.
Click here to create a free account and enable WCAG compliance in your cookie banner with just a few easy steps.
