Will Roberts | 25 August 2025

Creating an inclusive and compliant digital experience is no longer optional; it’s a legal and ethical imperative. For NHS trusts and private healthcare providers, accessibility is central to patient experience and safety. With the release of WCAG 2.2 (Web Content Accessibility Guidelines) in October 2023, there are now new success criteria that affect how healthcare websites should be designed and built.

In this comprehensive checklist, we’ll break down what WCAG 2.2 requires, what’s changed since WCAG 2.1, and how healthcare organisations can ensure their websites are compliant, user-friendly, and ready for the future.

What is WCAG 2.2?

WCAG (Web Content Accessibility Guidelines) are internationally recognised standards developed by the W3C (World Wide Web Consortium) to ensure digital content is accessible to users with disabilities.

WCAG 2.2 builds on the previous 2.1 version by introducing nine new success criteria, bringing the total to 86. These are designed to improve accessibility for users with:

Cognitive disabilities
Low vision
Motor impairments

The guidelines are structured around four core principles:

Perceivable
Operable
Understandable
Robust

A man is seated at a desk, working on a laptop and an additional monitor in an office environment. Another person is seen in the background walking away.

A man in a blue shirt is seen talking during a meeting, seated at a wooden table, with another person partially obstructing the foreground.

Why Accessibility Matters in Healthcare

For healthcare organisations, accessibility goes beyond compliance; it directly impacts lives. Patients and carers rely on healthcare websites to:

Access urgent care information
Book appointments
Review test results
Navigate services during critical moments

Inaccessible websites can lead to:

Legal risk under the UK Equality Act 2010
Reputational damage
The exclusion of vulnerable users from essential healthcare

Accessible website design and development isn’t just good practice; its an essential part of modern patient care.

Three individuals are seated at a table with laptops, engaged in discussion. A couple of drinks are on the table, and sunlight filters through the large window blinds behind them.

What’s New in WCAG 2.2

Here’s a breakdown of the nine new success criteria added in WCAG 2.2 and how they apply to healthcare websites.

Focus Not Obscured (Minimum) – 2.4.11 (AA)

Focus indicators must be at least partially visible. Users navigating by keyboard (e.g. with a tab key) need to see where they are on the page.
Example: If your “Book an Appointment” button is obscured by a sticky footer, it may fail this criterion.

Focus Not Obscured (Enhanced) – 2.4.12 (AAA)

A stricter requirement – focus indicators must be fully visible at all times.

Focus Appearance – 2.4.13 (AAA)

Focus indicators must have a clear contrast and sufficient size (at least a 2px border or equivalent) to be seen by low-vision users.
Tip: Avoid faint outlines or subtle glows for form fields and CTAs.

Dragging Movements – 2.5.7 (AA)

If your site requires users to drag elements (e.g. in an interactive map), an alternative method must be available.
Fix: Allow keyboard-based interaction as an alternative to dragging.

Target Size (Minimum) – 2.5.8 (AA)

Clickable areas should be at least 24×24 pixels, ensuring they’re accessible on touch devices and for users with motor impairments.
Check: Small links like “FAQs” or icons near each other are often culprits.

Consistent Help – 3.2.6 (A)

If help options (chat, phone, email) are offered, they must be consistently available across relevant pages.
Healthcare relevance: Make sure contact options aren’t just on your homepage – they should also appear during critical journeys like referrals or login issues.

Redundant Entry – 3.3.7 (A)

Users shouldn’t be required to input the same data more than once in a session.
Fix: Store data temporarily within the session, and pre-fill fields where possible.

Accessible Authentication (Minimum) – 3.3.8 (AA)

Authentication processes must not require users to pass memory tests, puzzles or CAPTCHAs without offering alternatives.
Fix: Provide login by email or allow screen reader-friendly authentication methods.

Accessible Authentication (Enhanced) – 3.3.9 (AAA)

A stricter version of the above. No cognitive function test is allowed without an alternative.

Steps to Become WCAG 2.2 Compliant

Conduct an Accessibility Audit

An accessibility audit should use both automated tools and manual testing to assess your site. Tools like Axe, WAVE, and Lighthouse can identify some issues, but keyboard and screen reader testing is also essential. There are organisations that provide focus groups of people with accessible requirements, such as visual impairments, who undertake real-world testing. Drop us a message if you’d like to find out more.

Engage Users with Lived Experience

Accessibility testing is most meaningful when conducted with real patients using assistive tech. Involve diverse users in your audits to uncover hidden friction points.

Document and Prioritise Fixes

Build an internal WCAG 2.2 checklist. Create tasks by success criterion and prioritise based on user risk and visibility.

Plan for Ongoing Compliance

Accessibility is not a one-time fix. Assign a team member responsibility, incorporate it into QA workflows, and revisit the guidelines during redesigns.

Choose the Right Digital Partner

Work with an agency that not only understands WCAG but also has experience delivering accessible, patient-centred solutions for healthcare.

Summary

With WCAG 2.2 now in force, healthcare organisations must raise the bar for accessibility – both to comply with the law and to deliver inclusive care for every user. The good news is that each change enhances usability for all visitors, not just those with specific needs.

Whether you manage a hospital website, a care home group website, or a private practice platform, now is the time to take stock and improve your digital accessibility.

Ready to get started?
Apply for a free digital audit or contact us to explore how your site can better meet the needs of every patient.