What Your Website Must Meet Under WCAG 2.1 and 2.2

The WCAG are the worldwide guidelines for accessible websites. In Germany, the law requires the middle level, Level AA of WCAG 2.1, set out through the European standard EN 301 549. You do not need to know the guidelines by heart, but you do need to understand their logic: four principles, three levels, one clear goal. This article explains both without jargon, so you know exactly what your company website must meet.

WCAG, BFSG, and EN 301 549: How Do They Fit Together?

Three acronyms come up again and again when accessibility is the topic. They sound complicated, but they describe a simple chain: a technical foundation, a European standard, and a German law.

The Three Terms Briefly Explained

• WCAG: The Web Content Accessibility Guidelines from the W3C are the international technical foundation. In versions 2.1 and 2.2, they describe how accessible web content must be designed on a technical level.
• EN 301 549: The European standard makes the WCAG binding across Europe and adds its own points. For web content, it adopts the WCAG criteria up to and including Level AA.
• BFSG: The Barrierefreiheitsstärkungsgesetz (Accessibility Reinforcement Act) is the German law that implements these requirements. Since June 28, 2025, it obligates many companies with digital products and services for consumers to be accessible.

For you, this means: no matter which route brings you under the obligation, the practical benchmark is always WCAG 2.1 Level AA in the end. This logic is not a German peculiarity. The European Accessibility Act and the United States' Section 508 also rely on the same WCAG criteria.

What Fines You Risk for Violations

Anyone who violates the BFSG risks not only formal warnings but also fines. Depending on the violation, the law provides for fines of up to 100,000 euros. This obligation, however, is only one side of the coin. The other is reach, because 7.9 million people with a recognized severe disability live in Germany, which is 9.3 percent of the population.

What Is the WCAG and Why Does It Concern Your Company?

What Does WCAG Mean?

WCAG stands for Web Content Accessibility Guidelines. They are published by the World Wide Web Consortium (W3C), the international body that develops the technical standards of the web. The WCAG guidelines describe how a website must be designed so that people with disabilities can use it. This does not mean only blind people. It is equally about people with limited vision, motor impairments, hearing impairments, or cognitive impairments.

Important for understanding this: accessibility helps far more people than disability statistics alone would suggest. A broken arm, glaring sunlight on a smartphone display, or a noisy environment without headphones all create temporary barriers too. If you build your website for the hardest case, you make it more usable for everyone. Therein lies the often overlooked business core: an accessible site is simply a better-made site.

For your company, the WCAG matters for one simple reason: nearly every accessibility law in the world refers to it. In Germany too, the WCAG does not appear directly in the law, but through the European standard EN 301 549 it is the technical benchmark against which public bodies, and since 2025 many companies as well, are measured. So if you want to know what an "accessible website" means technically, you always end up at the WCAG.

WCAG 2.0, 2.1, and 2.2: The Three Versions at a Glance

There are three versions that matter today. WCAG 2.0 was published in 2008, WCAG 2.1 on June 5, 2018, and WCAG 2.2 on October 5, 2023. Each new version builds on the previous one and adds to it, without removing older requirements. Anyone who meets WCAG 2.2 therefore automatically meets 2.1 and 2.0 as well.

Which WCAG Level Must Your Website Meet?

Level A, AA, and AAA Compared

The WCAG has three conformance levels: A, AA, and AAA. They describe how far accessibility extends. Level A covers the most basic requirements, without which a website would not be usable at all for some people. Level AA additionally includes the criteria that make the biggest difference in practice, such as sufficient color contrast. Level AAA is the strictest stage and in many cases is not even achievable for an entire website.

Why Level AA Is the Legal Benchmark

In practice, a clear rule of thumb applies: Level AA is what is required. The European standard EN 301 549, on which the Accessibility Reinforcement Act is based, adopts the criteria of WCAG 2.1 up to and including Level AA. You do not need to aim for AAA. The W3C itself explicitly does not recommend AAA as a general goal for complete websites.

An example makes the difference tangible. On the topic of color contrast, Level A does not yet require any minimum value, Level AA requires a clearly measurable contrast between text and background, and Level AAA tightens this value considerably once more. In practice, many websites already fail the AA requirement, because light gray tones on a white background look modern but are barely legible for older users or those with impaired vision. The required AA level is therefore not a bureaucratic detail but addresses exactly the problems that real people experience every day.

That is good news for decision-makers. You do not have to implement the technical maximum, but rather a clearly defined, achievable level. Whether this obligation applies to your company at all depends on your industry and your offering. You can answer that question fastest with our BFSG quick check, which shows whether the BFSG applies to you.

The Four Principles of the WCAG, Simply Explained

Behind the many individual WCAG criteria there are just four basic ideas. In English, their initial letters form the memorable word POUR. The four principles are: perceivable, operable, understandable, and robust. If you understand these four terms, you understand the entire guideline.

Perceivable

Every piece of information must be available to the senses. An image needs alternative text so that a screen reader can read it aloud. A video needs captions. Text needs enough contrast against the background so that people with weak vision can read it too. No one should be excluded from information simply because they cannot see or hear it.

Operable

The website must be fully controllable, even without a mouse. Many people use the web exclusively via the keyboard or via assistive tools that emulate a keyboard. Every link, every form field, and every button must therefore be reachable and triggerable with the Tab key. Allowing enough time for input and avoiding flickering content also belong here.

Understandable

This principle is about content and operation. Text should be clearly worded, navigation should be predictable, and forms should clearly explain what should be entered and what to do if there is an error. A page that is technically accessible but confusing in its content helps no one.

Robust

This is the technical principle. The code must be clean enough that current and future assistive tools interpret it correctly. This is where it becomes clear why a website's technical foundation is so important. Clean, semantic HTML is the prerequisite for a screen reader to recognize a heading as a heading and a button as a button.

From the Principles to the Testable Success Criteria

These four principles are deliberately kept abstract. Beneath them hang the concrete, testable success criteria, each of which is assigned to one of the three levels A, AA, or AAA. As a decision-maker, you do not need to know the individual criteria. It is enough to keep the four terms in mind as a checklist: can everyone perceive it, can everyone operate it, does everyone understand it, and is it built cleanly on a technical level? If you ask these four questions for every new feature, you avoid most barriers from the start.

What Changed with WCAG 2.2?

Nine New Success Criteria Compared to WCAG 2.1

WCAG 2.2 is not a revolution but an extension. It adds nine additional success criteria compared to WCAG 2.1. Most of them concern details that remove real hurdles in everyday use. These include, for example, that the keyboard focus must not be hidden by other elements, that clickable areas should have a minimum size, and that login processes should work without memory tests such as typing out codes.

One change is especially relevant in practice: the old criterion 4.1.1 on correct code markup was removed as obsolete in WCAG 2.2, because modern browsers now fulfill its original purpose themselves. You do not need to memorize these criterion numbers. What matters is the direction: the WCAG is continuously adapted to real-world use, such as operation by smartphone and touchscreen. The larger clickable areas in WCAG 2.2 in particular are a direct concession to the fact that most people are on mobile devices today.

WCAG 2.1 or 2.2: What You Should Rely On Today

So should you rely on 2.1 or 2.2 today? In Germany, Level AA of WCAG 2.1 is currently the legally binding standard. Even so, anyone building anew should orient themselves toward WCAG 2.2. The extra effort is small, and you build your website to be future-proof rather than chasing a legal level that is clearly set to rise. For more on the big picture, see our complete overview of web accessibility.

Which WCAG Errors Are Most Common on Company Websites?

The Three Most Common WCAG Violations

The good news first: most violations are not exotic special cases but always the same classics. The WebAIM Million Report 2025 tested one million home pages and found measurable WCAG errors on 94.8 percent of them, an average of 51 errors per page. If you know these top errors, you know where to start first.

Three problems lead the list. Insufficient text contrast affects 79.1 percent of pages, missing alternative text for images affects 55.5 percent, and missing form labels affect 48.2 percent. All three can be assigned directly to the four principles: contrast and alternative text belong to "perceivable," labeled forms to "understandable." Therein lies the practical value of the four-principle model. It assigns every error to a clear category.

Why the Technical Foundation Determines the Effort

What stands out is that almost all of these errors fall under the responsibility of the technical implementation, not the editorial team. A contrast is determined in the design, a form label in the code. On a modern, component-based system, a button built correctly once is used correctly everywhere. On a site that has grown over years with many add-ons, by contrast, every spot often has to be fixed individually. In projects with B2B clients, I see again and again that the clean technical foundation is what ultimately decides the effort and cost.

At Evelan, we rely on a stack of Next.js and a headless CMS, because clean, semantic HTML is the rule there and not the exception. That feeds directly into the WCAG principle "robust" and reduces the effort of keeping a website conformant. To learn how much an accessible implementation costs, read our article on what an accessible website costs.

How Do You Check Whether Your Website Meets the WCAG?

Automated WCAG Tools and Their Limits

Many companies' first reflex is a free online tool. Programs like axe, WAVE, or the Lighthouse built into Chrome scan a page in seconds and deliver a list of errors. That is a sensible start, but only half the truth. Automated tools uncover only part of the WCAG problems, far from all. They detect a missing alternative text but cannot judge whether an existing text is actually meaningful.

Manual Testing with Keyboard and Screen Reader

An important second part is manual testing. Here the page is operated exclusively by keyboard and gone through with a screen reader, just as affected people do every day. Only then does it become clear whether the order is logical, whether the focus stays visible, and whether forms are truly understandable.

Another building block, not the most important but often underestimated, is testing with real users. When people with disabilities actually operate your website, hurdles come to light that neither a tool nor a checklist captures. For many small and mid-sized businesses, this is not a mandatory step, but even two or three pieces of feedback from practice are often more revealing than any automated report. A serious assessment therefore does not rely on a single tool but combines several layers. The following checklist helps you roughly assess your own website before you commission a professional review.

Related Evelan Articles

• Accessible Website: The Guide for Companies
• BFSG Quick Check: Does the Accessibility Obligation Apply to My Website?
• Having an Accessible Website Built: Costs, Process, and What Agencies Don't Tell You
• Website Relaunch as an Investment in the Future

Sources

• W3C Web Accessibility Initiative: WCAG 2 Overview (2023)
• W3C Web Accessibility Initiative: What's New in WCAG 2.2 (2023)
• WebAIM: The WebAIM Million, Annual Accessibility Analysis of the Top 1,000,000 Home Pages (2025)
• Federal Monitoring Agency for the Accessibility of Information Technology: Harmonized European Standard EN 301 549 (2025)
• Federal Office for Accessibility (Bundesfachstelle Barrierefreiheit): The Accessibility Reinforcement Act (BFSG), Overview and Entry into Force (2025)
• gesetze-im-internet.de: BFSG Section 37, Fine Provisions (2025)
• Federal Statistical Office (Statistisches Bundesamt): 7.9 Million People with Severe Disabilities Live in Germany (2024)