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What WCAG 2.1 AA means for a small online shop, in plain English

"WCAG 2.1 AA" comes up constantly when people talk about website accessibility. Here is what it means, without the jargon, for someone running a small online shop.

What WCAG is

The Web Content Accessibility Guidelines (WCAG) are a technical standard published by the World Wide Web Consortium (W3C), which explains how to make web content more accessible to people with disabilities (WCAG 2 Overview (W3C Web Accessibility Initiative)).

What "AA" means

Each WCAG requirement (called a "success criterion") has a level: A, AA or AAA (WCAG 2 Overview (W3C Web Accessibility Initiative)). "Meeting AA" means meeting all the Level A and Level AA requirements. AAA is the strictest level. The W3C itself says it is "not recommended that Level AAA conformance be required as a general policy for entire sites because it is not possible to satisfy all Level AAA success criteria for some content" (WCAG 2.1, Conformance Requirements (W3C)).

The four principles

WCAG is organised under four principles (WCAG 2 at a Glance (W3C WAI)):

  • Perceivable: people can see or hear the content, for example images have text alternatives and videos have captions.
  • Operable: people can use it, for example everything works from a keyboard.
  • Understandable: the content and controls are clear and predictable, and help people avoid and fix mistakes.
  • Robust: it works with assistive technologies such as screen readers.

The requirements that matter most on a store

WCAG 2.1 has many success criteria (Web Content Accessibility Guidelines (WCAG) 2.1 (W3C Recommendation)). These are the ones that most often come up on small stores:

Selected WCAG 2.1 success criteria, explained for online shops
Criterion (level)In plain English, on a store
1.1.1 Non-text Content (A)Product photos, banners and icon buttons have text alternatives.
1.3.1 Info and Relationships (A)Headings, lists, tables and form labels are built with proper code, not just styled to look right.
1.4.3 Contrast (Minimum) (AA)Text has at least 4.5:1 contrast (3:1 for large text).
1.4.4 Resize Text (AA)Text can be zoomed to 200% without breaking the page.
1.4.10 Reflow (AA, new in 2.1)The store works on a narrow screen without sideways scrolling.
1.4.11 Non-text Contrast (AA, new in 2.1)Buttons, input borders and icons are visible enough (3:1).
2.1.1 Keyboard (A)Menus, product options, cart and checkout all work without a mouse.
2.4.4 Link Purpose (A)Links make sense, so not ten "Shop now" links that go to different places with no context.
2.4.7 Focus Visible (AA)Keyboard users can see where they are on the page.
3.3.2 Labels or Instructions (A)Form fields (email, quantity, size) have labels.
4.1.2 Name, Role, Value (A)Custom buttons, toggles and pop-ups tell screen readers what they are and what state they are in.

How this relates to the ADA

We can only point you to what official sources say, not tell you how they apply to your situation. The Department of Justice's position is that the ADA applies to businesses open to the public, including what they offer online. Its 2022 guidance also says the Department "does not have a regulation setting out detailed standards" for businesses' websites, that businesses currently have flexibility in how they make their online goods and services accessible, and that existing technical standards such as WCAG and the Section 508 Standards "provide helpful guidance" (Guidance on Web Accessibility and the ADA (ADA.gov, U.S. Department of Justice, March 18, 2022)).

The same page notes that DOJ guidance documents have no legally binding effect (Guidance on Web Accessibility and the ADA (ADA.gov, U.S. Department of Justice, March 18, 2022)).

In April 2024 the DOJ published a rule that adopts WCAG 2.1 Level AA as the technical standard for the websites and mobile apps of state and local governments (Title II of the ADA). In April 2026 it extended that rule's compliance dates to April 2027 and April 2028, depending on population (Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments (ADA.gov, updated after the April 20, 2026 Interim Final Rule)). That rule is about public entities such as cities, counties and public schools. It is not a rule for private businesses such as online shops, which fall under a different part of the ADA (Title III) (Guidance on Web Accessibility and the ADA (ADA.gov, U.S. Department of Justice, March 18, 2022)).

Courts have also not all approached websites the same way. For example, in 2019 the U.S. Court of Appeals for the Ninth Circuit held that the ADA applied to Domino's website and app, and described the "nexus" between the website and app and Domino's physical restaurants as "critical to our analysis" (Robles v. Domino's Pizza, LLC, No. 17-55504 (9th Cir. Jan. 15, 2019), opinion (PDF)). Many small online shops have no physical store at all, which is one more reason to ask a lawyer how these questions apply to you. In 2021 a panel of the Eleventh Circuit held that websites are not places of public accommodation under Title III (Gil v. Winn-Dixie Stores, Inc., No. 17-13467 (11th Cir. Apr. 7, 2021), opinion (PDF)), but the court later vacated that opinion because the case had become moot (Gil v. Winn-Dixie Stores, Inc., No. 17-13467 (11th Cir. Dec. 28, 2021), order vacating the opinion as moot (PDF)). State laws can matter too: California's Unruh Civil Rights Act, for example, says that a violation of a person's rights under the ADA is also a violation of that Act (California Civil Code section 51 (Unruh Civil Rights Act), California Legislative Information).

These are only examples to show that the legal picture is not simple, and they are not a summary of the law. Which rules apply to your store depends on facts such as where you and your customers are, so please talk to a lawyer about your own legal obligations.

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Technical fixes, not legal advice. This guide explains website accessibility from a technical point of view. We are not a law firm, and nothing here is legal advice. No scan, fix or guide can guarantee legal compliance, the outcome of any demand letter or lawsuit, or protection from future claims. If you have received a legal claim, please consult a qualified attorney about it.

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