Do we need WCAG 3 (now)?


Earlier this week, W3C/WAI announced that Web Content Accessibility Guidelines (WCAG) 2.2 is now at the last hurdle before becoming a standard. This is huge news because its precursor WCAG 2.1 is the basis of a lot of accessibility policy and laws. For example, the European Accessibility Act (EAA) makes web accessibility mandatory for most commercial websites. The requirements are set in the European Norm EN 301 549 which explicitly directly references WCAG 2.1.

While WCAG 2 (and 2.1, and 2.2) has its flaws, like every standard has, it is a very successful standard. The whole accessibility industry has rallied around it, it is referenced by the International Association of Accessibility Professionals (IAAP)1 in their certification programs.

In addition, we have fifteen years of experience with WCAG 2 now. Tooling, practices, expectations have been set. We have found guidance and documentation that is misleading or insufficient and corrected it over the years.2 We learned to explain the requirements and the ins and outs of how to address different failures.

And I think the knowledge of seeing a pattern in a code and knowing how to best meet or exceed WCAG is really what an accessibility professional can bring into a team. Identifying that something passes or fails is relatively simple, taking clients by the hand and guiding them to conformance is much harder3 . And experience helps a lot in this regard.

W3C/WAI also announced a new Working Draft of WCAG 3, the next generation standard. Confusingly enough, apart from the abbreviation, WCAG 3 will have nothing in common with WCAG 2. Not even its name which is planned to become W3C Accessibility Guidelines 34 . This draft highlights the highly experimental nature of this specification right now.

I have written about the WCAG 3 not being ready in 2021 and this is the first update since then. I would suspect that it will take at least until the end of the decade to see WCAG 3 come to fruition, if that fast. The W3C/WAI has a good overview of the changes that might be coming in WCAG 3.

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I'm a web accessibility professional who cares deeply about inclusion and an open web for everyone. I work with Axess Lab as an accessibility specialist. Previously, I worked with Knowbility, the World Wide Web Consortium, and Aktion Mensch. In this blog I publish my own thoughts and research about the web industry.

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Do we need a revolution?

“[T]his is another positive step toward a much needed revolution of WCAG.” writes Léonie Watson in LinkedIn.

I don’t fully agree. Producing a new standard seems to be a solution to some of the issues that WCAG has, mainly the intermixing of guidance and conformance, hard to read language or limits of where WCAG 2 applies due to new technologies.

That said, the base principles of accessibility (perceivable, operable, understandable, and robust) will not change. WCAG 2 compliant sites won’t be inaccessible once the standard is published. Indeed, W3C/WAI says that WCAG 2 will exist long after WCAG 3 is published: “WCAG 3 will not supersede WCAG 2, and WCAG 2 will not be deprecated, for at least several years after WCAG 3 is finalized.”

Let’s say WCAG 3 is finalized in 20295 and the transition period is five years until 2035, then this gives companies a decision point for quite a long time: Can I change to WCAG 3 while WCAG 2 is legally required? Do I have to conform to both to be future-proof?

Testers and auditors on the other side must cater for two different types of tests every time they start an audit. Sometimes they might need to use ruleset A and other times B and sometimes a combined AB ruleset. And if that wasn’t making it complicated enough, one of the goal of WCAG 3 is to move away from the binary pass/fail criteria of WCAG 2 to a graded, well, grade.

While this sounds useful in practice, there is a lot of bookkeeping involved. Currently, if an image has no alternative text (and should have one), that page fails SC 1.1.1 Non-Text Content. In the future, the amount of images might have an impact on the conformance. Test Scopes describes the current thinking of the group (the section is marked as “developing”). I think this kind of scoring will work great for large companies with in-house testers and processes, but it will make it much harder for individuals or small consultants. This part of the standard could probably be its own separate testing standard.

And indeed with WCAG 2, we have Evaluation Methodology (WCAG-EM) that does some of this.


WCAG 2 has shown over 15 years that it can be shaped into a better standard with incremental updates. It feels wasteful that we are training people and companies on WCAG 2.2 in the next five years, only to then pivot to the shiny new thing. Which in practice will not be a significant improvement for disabled people, apart from the new cognitive requirements that, by definition, cannot fall into the pass/fail scheme of WCAG 26 .

That said, why could the conformance model of WCAG 2 not be adapted to these requirements? Could WCAG 2 reference another standard that has more of these “squishy” requirements? I think it is totally in the realm of a standard like WCAG to say “here are the practices for readable text” and then leave it to the reviewer to make the argument for pass/fail.

CSS is the other successful standard at W3C/WAI. It works because it is an iterative improvement. Like WCAG 2, it is only additive. Unlike WCAG 2, it is developed in modules. Have a good idea for a CSS module? Spec it, have it implemented, and voilà, it’s part of CSS. This should be the way WCAG 2 works, too. If there is a new color contrast approach, why not put that into its own module, mature it on its own and when that has happened, add it to the next version of WCAG 2.

W3C wanted to reinvent an important standard, HTML, in the early 2000s. XHTML, an XML version of HTML, was supposed to be the next version. It broke compatibility with many previous HTML implementations and practices. And, in the end, it failed. W3C lost HTML to the What Working Group. If WCAG 2 is still used by laws and policies but W3C/WAI does not want to further develop it, there might be a gap for people who want to continue with the tried ways of WCAG 2.

On the other hand, how good is a WCAG 3 that only gets updated like WCAG 2, every 5 to 10 years? In any case, the rate of updates needs to increase. WCAG 2 has hundreds of open issues and pull requests, mostly for supplemental guidance like the Understanding and the Techniques. And exactly those types of information is what WCAG 3 is thinking about to update frequently. The question is: Will this be done? Understanding, Techniques and other documents are already supposed to be up-to-date. But even the correction for minor typos are often not published.7


I know that the people who are working on WCAG 3 have the right intentions. It just doesn’t fill me with confidence to see so many issues and pull requests open for a standard and its supporting documents. As far as I can see, WCAG 2 will be on life support at best in the coming years.

I would not want to switch places with people new to the accessibility field – be it as designers, developers, or testers – in the coming years. We have a long transitional phase in front of us. This would be OK if WCAG 2 was a universally understood and applied baseline. But it is not. Most websites fail WCAG, and I don’t think that will change over the next years, also not with a new standard overnight.

For me, WCAG 3 currently feels like a big distraction, the candy you are not allowed to have for a long time. And then you need to develop tools, and teach the standard to people, and lobby for adoption. All while WCAG 2 is there and could be improved.

Support Eric’s independent work

I'm a web accessibility professional who cares deeply about inclusion and an open web for everyone. I work with Axess Lab as an accessibility specialist. Previously, I worked with Knowbility, the World Wide Web Consortium, and Aktion Mensch. In this blog I publish my own thoughts and research about the web industry.

Sign up for a €5/Month Membership Subscribe to the Infrequent Newsletter Follow me on Mastodon

  1. Quick acknowledgement that both, W3C and IAAP, are allowing memberships of companies selling dubious accessibility overlays.
  2. Huge shoutout to everyone who has contributed to issues and pull requests!
  3. Of course, conformance should never be the end goal. But IMHO, it is a necessary stepping stone towards an inclusive product.
  4. And yes, I am unreasonably bothered by WCAG 2, 2.1, and 2.2 having /TR/wcag2, /TR/wcag21, and /TR/wcag22 URL slugs respectively, and this one has /TR/wcag-3.0.
  5. See, I can be optimistic!
  6. Again, the principles for accessibility stay the same, and I’m convinced that if there are gaps, those can be filled in WCAG 2, too – if the Working Group would choose to do it.
  7. Like my evergreen “refow” typo in the quick reference.

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