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WCAG 2.2 AA for Publishers: A Plain English Guide

April 2, 2026·8 min read

WCAG 2.2 AA is the international standard for digital accessibility. It applies to websites, apps, and — increasingly through regulation — to digital books and reading platforms. The European Accessibility Act, the UK Equality Act, and the US ADA all reference WCAG as the technical benchmark for accessibility compliance.

For publishers and authors, understanding WCAG 2.2 AA means understanding what accessible digital content is required to do — and what failing to meet that standard means for your legal exposure.

What Is WCAG?

WCAG stands for Web Content Accessibility Guidelines, published by the W3C (World Wide Web Consortium) — the international body that maintains web standards. While "web content" is in the name, WCAG is now widely applied to any digital content, including EPUB eBooks, digital learning materials, and publisher portals.

The guidelines are organised around four principles, known as POUR:

PrincipleMeaning
**Perceivable**Content can be perceived by all users, including those using screen readers or magnification
**Operable**All functionality can be operated without a mouse (keyboard navigation, touch)
**Understandable**Content and navigation are clear and consistent
**Robust**Content is compatible with current and future assistive technologies

Under each principle are specific Success Criteria — testable requirements your content must meet. WCAG has three conformance levels:

  • Level A: — minimum accessibility requirements
  • Level AA: — the standard required by most regulations worldwide, including the EAA
  • Level AAA: — the highest level, typically not required by law but recommended for specialist audiences

    • WCAG 2.2 vs WCAG 2.1

    WCAG 2.2 was published in October 2023. It is backward-compatible with WCAG 2.1 — everything that was required in 2.1 is still required in 2.2. WCAG 2.2 adds nine new success criteria, including stricter focus visibility requirements and new requirements for mobile accessibility.

    The European Accessibility Act currently references WCAG 2.1 AA as the minimum standard. Meeting WCAG 2.2 AA satisfies the EAA and provides future-proofing against upcoming regulation updates.

    Key WCAG 2.2 AA Requirements for Digital Books

    ### 1. Text Alternatives (Perceivable — 1.1.1)

    Every non-text element — images, charts, graphs, diagrams — must have a text alternative that serves the same purpose.

    For EPUB: every `` element requires an `alt` attribute with a meaningful description. Decorative images use `alt=""` to signal to screen readers that the image should be ignored.

    What this means in practice: A graph showing sales data needs an alt text that describes the data, not just "sales graph." A decorative border image needs an empty alt attribute.

    ### 2. Captions for Audio-Visual Content (Perceivable — 1.2)

    Any audio or video content must have captions (for audio tracks) and audio descriptions (for visual content in video). This applies to enhanced eBooks with embedded media.

    ### 3. Adaptable Content (Perceivable — 1.3)

    Content must be structured so that it can be presented in different ways without losing information. In EPUB terms, this means:

  • Using semantic HTML elements (`<h1>`–`<h6>`, `<p>`, `<ul>`, `<table>`)
  • Not conveying information through visual presentation alone (e.g. "click the red button")
  • Ensuring reading order matches the intended logical order

    • ### 4. Distinguishable Content (Perceivable — 1.4)

    Colour contrast must meet minimum ratios:

  • Normal text:: 4.5:1 contrast ratio between text and background
  • Large text (18pt+ or bold 14pt+):: 3:1 minimum
  • Non-text elements (icons, charts):: 3:1

    • Information must not be conveyed by colour alone.

    ### 5. Keyboard Accessible (Operable — 2.1)

    All functionality must be operable without a mouse. For reading platforms, this means chapter navigation, table of contents, search, and all interactive features must be keyboard-accessible.

    ### 6. Focus Visible (Operable — 2.4.11, 2.4.12 — new in WCAG 2.2)

    The keyboard focus indicator must be visible and meet minimum size requirements. This is relevant primarily for reading platform interfaces.

    ### 7. Enough Time (Operable — 2.2)

    If content moves, blinks, or auto-updates, users must be able to pause it. Relevant for enhanced eBooks with animated content.

    ### 8. Readable Content (Understandable — 3.1)

    The language of the document must be declared in the HTML. In EPUB, this is set in the OPF metadata: `en`. Language changes within the text must also be marked up.

    ### 9. Input Assistance (Understandable — 3.3)

    For interactive content — forms, quizzes in educational eBooks — errors must be identified and described to the user.

    ### 10. Compatible with Assistive Technology (Robust — 4.1)

    Content must parse correctly. For EPUB, this means:

  • Valid, well-formed HTML
  • No duplicate IDs
  • Correct ARIA role usage
  • Elements have accessible names where required

    • WCAG 2.2 AA vs EPUB Accessibility 1.1

    WCAG 2.2 AA is the technical standard. EPUB Accessibility 1.1 is the publishing-specific standard that incorporates WCAG and adds EPUB-specific requirements:

  • Accessibility metadata in the OPF file
  • Reading order conformance
  • ARIA landmark roles (e.g. `epub:type="bodymatter"`)
  • Certification metadata (`a11y:certifiedBy`)

    • For publishers, the practical goal is EPUB Accessibility 1.1 conformance — which requires WCAG 2.1 AA (minimum) and adds the publishing-specific layer. Meeting WCAG 2.2 AA and EPUB Accessibility 1.1 together satisfies both the EAA and DAISY certification requirements.

    How to Test for WCAG 2.2 AA Compliance

    ### Automated Testing

    Automated tools catch approximately 30–40% of WCAG violations. For EPUB:

  • DAISY Ace: — runs a WCAG-mapped scan of your EPUB file and generates an HTML report
  • axe DevTools: — browser-based WCAG testing for web interfaces
  • Contrast Analyser: — a free desktop tool for checking colour contrast ratios

    • ### Manual Testing

    The remaining 60–70% of WCAG requirements require human judgement:

  • Navigate the content using a screen reader (NVDA + Chrome on Windows; VoiceOver + Safari on Mac)
  • Navigate using keyboard only
  • Review all alt text for accuracy and meaningfulness
  • Check reading order matches visual order

    • ### Assistive Technology Testing

    Test your EPUB on actual reading applications used by readers with disabilities:

  • VoiceOver on iOS/macOS: with Apple Books
  • NVDA/JAWS with Thorium Reader: on Windows
  • TalkBack on Android: with Readium

    • Common WCAG Failures in Publisher Content

    Based on typical EPUB accessibility audits, these are the most frequently failing criteria:

  • **Missing or inadequate alt text** — images present with empty or unhelpful alt attributes
  • **Incorrect heading hierarchy** — visual heading styles used instead of `<h1>`–`<h6>` elements
  • **Colour contrast failures** — particularly in sidebars, footnotes, and caption text
  • **Missing language declaration** — OPF missing `<dc:language>` or XHTML pages missing `lang` attribute
  • **Table accessibility** — data tables without `<th>` headers or `scope` attributes
  • **Reading order mismatch** — content flows in the wrong order when linearised

    • Frequently Asked Questions

    Does WCAG apply to eBooks or only websites?

    WCAG was originally written for web content but is now applied broadly to any digital content, including EPUB eBooks, through legislation like the European Accessibility Act (EU), Section 508 (US government), and the UK Equality Act. EPUB Accessibility 1.1, which is the eBook-specific standard, incorporates WCAG as its core technical requirement.

    What is the penalty for failing to meet WCAG 2.2 AA?

    Penalties are enforced at the national level in the EU under the EAA. In the US, Section 508 violations can result in federal contractor debarment; ADA violations can result in civil litigation. Penalties vary by jurisdiction and the nature of the failure, but the risk of complaint-driven enforcement is real and increasing.

    How do I know what WCAG level my EPUB currently meets?

    Run your EPUB through DAISY Ace. The report will show which success criteria pass and which fail, organised by POUR principle. Our HoloRemedi platform runs this automatically on upload and displays results in a visual compliance dashboard.

    Is WCAG 2.2 AA the same as Section 508 compliance?

    Section 508 (US federal law) references WCAG 2.0 Level AA. In practice, meeting WCAG 2.2 AA satisfies Section 508 requirements and goes further — WCAG 2.2 is a superset of WCAG 2.0.

    Can AI generate compliant alt text?

    AI tools can generate high-quality alt text for most common image types — photographs, simple diagrams, charts. For complex scientific figures, mathematical diagrams, and images where domain knowledge is required to convey meaning accurately, human review of AI-generated alt text is essential.

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    Holograph PressWorks remediates EPUB and PDF files to WCAG 2.2 AA and EPUB Accessibility 1.1 standards using our HoloRemedi platform. Every project includes official Ace and VeraPDF compliance reports. [Request a consultation →](/contact-us)