If you are designing digital products in 2025, accessibility is no longer just a “nice-to-have” feature—it is a legal imperative. I’ve sat in countless stakeholder meetings over the last decade where accessibility was pushed to “Phase 2,” only to never see the light of day. But with the April 2024 ADA Title II updates and the looming European Accessibility Act, failing to meet the latest standards isn’t just bad UX; it’s a massive liability.

The landscape has shifted beneath our feet. We are no longer just talking about color contrast. We are talking about strict cognitive load requirements, minimum target sizes that affect your grid systems, and legal mandates that apply to public entities and private businesses alike.

This guide breaks down the 9 new WCAG 2.2 criteria, explains the 2025 legal landscape without the legalese, and provides a designer-friendly checklist to keep your projects compliant and inclusive.

In my experience, that 96.3% failure rate isn’t because designers don’t care—it’s because the standards are complex and often buried in technical documentation. Let’s fix that.

The New Global Standard: Understanding WCAG 2.2

The Web Content Accessibility Guidelines (WCAG) 2.2 became the official recommendation in late 2023, but 2024-2025 is when we are seeing strict adoption. While WCAG 2.1 focused heavily on mobile accessibility, WCAG 2.2 takes a massive leap forward for users with cognitive disabilities and motor limitations.

Why the update? Because the web has changed. We have more sticky headers, more drag-and-drop interfaces, and more complex authentication flows than ever before.

The 9 New Success Criteria: A Designer’s Translation

You don’t need to memorize the code specs, but you must understand the design constraints. Here are the critical updates affecting your UI files:

1. Focus Not Obscured (Minimum & Enhanced)

The Problem: You’ve likely designed a sticky header or a chat widget that floats at the bottom of the screen. When a keyboard user tabs through links, the focus indicator often disappears behind these sticky elements.

The Fix: Design your layouts so that the item receiving focus is always at least partially visible. In Figma, this means checking your “scroll to” interactions to ensure sticky elements don’t overlay the focused content.

2. Dragging Movements

The Problem: Kanban boards and sliders often require a “drag” gesture. For users with fine motor control issues, holding down a mouse button while moving it is incredibly difficult.

The Fix: Always provide a single-pointer alternative. If you have a slider, allow users to tap anywhere on the bar to jump to that value, or provide +/- buttons.

3. Target Size (Minimum)

This is perhaps the biggest change for mobile UI. While Apple recommends 44x44pt, WCAG 2.2 level AA now strictly mandates a minimum target size of 24×24 CSS pixels.

The Design Rule: If your icon is 16px, the clickable padding must extend to at least 24px. In my opinion, you should stick to the 44px standard for better usability, but 24px is now the hard floor for compliance.

4. Consistent Help

If you offer a chat bot, a contact number, or an email link, it must appear in the same location on every page. Don’t put the “Help” button in the header on the homepage and in the footer on the product page.

5. Redundant Entry

Stop making users type the same info twice. If a user enters their billing address, the shipping address form should auto-populate or offer a checkbox to “Same as billing.” This reduces cognitive load significantly.

6. Accessible Authentication

The Game Changer: Cognitive function tests are now forbidden for authentication unless there is an alternative. This means those “Select all traffic lights” CAPTCHAs or asking users to memorize a password without a paste option are non-compliant.

The Fix: Support password managers (don’t block pasting) and consider WebAuthn (biometrics) or magic links.

2024-2025 Legal Landscape Updates

If the ethical argument doesn’t move your stakeholders, the financial one will. The legal environment has become significantly more aggressive regarding digital accessibility.

The DOJ’s ADA Title II Final Rule (April 2024)

In a landmark move, the U.S. Department of Justice signed a final rule under Title II of the ADA. According to the ADA.gov Fact Sheet (April 2024), state and local governments must ensure their web content and mobile apps conform to WCAG 2.1, Level AA. While this specifically targets the public sector, Title III (businesses) litigation often follows Title II precedents closely.

Litigation is already rising. According to the Accessibility.com 2023 Year End Report, 3,225 website accessibility lawsuits were filed in federal court in 2022 alone. I expect this number to spike in late 2024 as the DOJ rule takes full effect.

European Accessibility Act (EAA) Deadline (June 2025)

This is the “GDPR moment” for accessibility. By June 28, 2025, the European Accessibility Act (EAA) will apply to a vast range of digital products and services. Crucially, this applies to US companies selling to EU consumers.

If your e-commerce site operates in Europe, you must comply. The EAA is broader than the ADA; it covers everything from ATMs to e-books and e-commerce services.

Key UI/UX Updates for Motor & Cognitive Accessibility

Designing for Touch: The 24×24 vs 44×44 Pixel Debate

One of the most confusing aspects for junior designers is the difference between “target size” and “visible size.” You can visually design a small, elegant 12px “info” icon, but the hit area must be larger.

According to WebAIM’s Screen Reader Survey #10 (Jan 2024), 72.5% of screen reader users rely on mobile apps. Small touch targets are a major barrier for them. While WCAG 2.2 sets the floor at 24px, the W3C WAI documentation suggests striving for 44px whenever possible to accommodate users with tremors or larger fingers.

Cognitive Load: Reducing Friction

We often think of accessibility as “blind users.” But the World Health Organization reports that an estimated 1.3 billion people experience significant disability. A massive portion of this includes neurodivergent users (ADHD, Dyslexia, Autism).

Design Tip: Avoid “wall of text” layouts. Use generous whitespace, bullet points, and clear headings. When designing forms, use inline validation that explains how to fix an error, rather than just highlighting the box in red.

Mobile App Accessibility Standards (iOS & Android)

Mobile accessibility is often the wild west compared to the web. However, with the new DOJ ruling covering mobile apps specifically, we have to tighten up.

Dynamic Type and Scaling

It isn’t enough to just pick a legible font size. Your app must respond to the user’s system settings. If a user sets their iOS text size to 200%, your layout must adapt—not break.

Fail: Text that gets cut off or overlaps when resized.

Pass: Layouts that stack vertically (reflow) when text size increases.

Haptics and Gestures

Never rely solely on color or sound to convey information. Haptics (vibrations) are great, but they must be supplemental. According to Click-Away Pound Survey, 71% of web users with a disability will simply leave a website or app that is not accessible. If your error state is just a red vibration, colorblind users or those with haptics disabled are lost.

The Future: AI and WCAG 3.0

We can’t talk about standards without mentioning Artificial Intelligence. AI is currently a double-edged sword for accessibility.

On one hand, AI tools are revolutionizing automated testing. However, Jared Smith from WebAIM notes that while automated tools are improving, they still only catch about 30-40% of accessibility errors. Human testing is non-negotiable.

Warning on Overlays: Many businesses try to install “accessibility overlays” (widgets that sit on your site) to fix compliance issues instantly. Do not rely on these. They often fail to correct underlying code issues and can actively interfere with screen readers. They do not provide legal protection.

Looking further ahead, WCAG 3.0 (Project Silver) is in draft status. It aims to move away from the strict “Pass/Fail” model to a more holistic scoring system. While not expected to be law for several years, following the principles of inclusive design now will future-proof your work.

Frequently Asked Questions (FAQ)

Is WCAG 2.2 mandatory in 2025?

It depends on your jurisdiction, but effectively, yes. While the ADA generally points to WCAG 2.1 AA as the legal benchmark for now, WCAG 2.2 is the technical recommendation. Designing to 2.2 ensures you meet 2.1 requirements while covering the latest device interactions.

What is the minimum button size for accessibility?

Under WCAG 2.2 Level AA, the target size must be at least 24×24 CSS pixels. However, passing the bare minimum is rarely good UX. Aim for 44×44 pixels (Apple) or 48×48 dp (Android) for a truly accessible experience.

Who needs to comply with the European Accessibility Act?

The EAA applies to manufacturers and service providers. This includes e-commerce services, banking services, e-books, and computers/smartphones. If you are a US company selling these services to EU customers, you must comply by June 28, 2025.

Does the ADA require WCAG 2.1 or 2.2?

The DOJ’s April 2024 Final Rule for Title II (state/local gov) specifically mandates WCAG 2.1 Level AA. However, because WCAG 2.2 is backward compatible, meeting 2.2 guarantees 2.1 compliance.

Conclusion

The shift to WCAG 2.2 and the enforcement of the ADA and EAA mark a turning point for the digital industry. We are moving away from accessibility as a checklist item and toward accessibility as a fundamental human right.

Remember the statistic: the combined disposable income of working-age adults with disabilities is $490 billion (Nucleus Research). By ignoring these standards, you aren’t just risking a lawsuit; you are ignoring a massive, economically powerful market segment.

Start your audit today. Focus on the new dragging movements, check your target sizes, and ensure your focus states aren’t obscured. Design for the margins, and you design better for everyone.