If you work in accessibility or are responsible for compliance at your organization, you’ve probably heard about WCAG 3.0. The W3C has been developing it for years, and the most recent Working Draft was released in September 2025. At first glance, it feels like a big leap forward: a standard that promises to address gaps in WCAG 2, bring in new ways of thinking about user needs, and tackle challenges like deceptive patterns and algorithmic harms.

That all sounds exciting, but here’s the reality: WCAG 3 is not ready for you to use as a compliance framework. Not even close.

The draft is still highly fluid. The conformance model, which is the part that tells you how to measure whether you’ve met the standard, is unsettled. The W3C has floated different options, from points to percentages to modular scoring, but nothing has been finalized. Entire sections are still labeled as “exploratory,” which is another way of saying the Working Group knows the goals but hasn’t figured out the test procedures. Key areas like cognitive accessibility, dark patterns, and artificial intelligence are included in broad strokes but lack the rigor that auditors, regulators, or legal teams would need to apply them consistently.

There’s also no formal migration guidance. The promise is that if you already meet WCAG 2.2 AA, you’ll be close to the base tier of WCAG 3. But “close” isn’t enough for an organization that needs clear continuity in its compliance posture. Add to that the fact that sampling rules for large websites and applications haven’t been written yet, and you can see the problem: WCAG 3 is basically still research. It isn’t yet a standard you can build your compliance program on.

Why WCAG 2.2 Still Matters

While WCAG 3 is evolving, the compliance world continues to run on WCAG 2.x. In the United States, the ADA and Section 508 both reference WCAG 2.0 or 2.1. In Europe, EN 301 549, which underpins the European Accessibility Act, maps directly to WCAG 2.1 AA. Canada, Australia, Israel, and many others also cite WCAG 2.0 or 2.1 in law or policy.

And WCAG 2.2, finalized in October 2023, is already becoming the de facto benchmark, especially in lawsuits. It introduces important new success criteria—accessible drag and drop, visible focus appearance, larger minimum target sizes—that reflect real usability issues today. By adopting WCAG 2.2 AA, your organization not only keeps pace with regulation but also aligns itself with what WCAG 3 will expect at its baseline. Investing in WCAG 2.2 compliance is not wasted effort; it is the most pragmatic and legally sound move you can make right now.

What Compliance Leaders Should Be Doing

If your job is to reduce risk, improve accessibility, and keep your organization compliant, your focus should stay firmly on WCAG 2.2. That starts with anchoring policies, procurement contracts, and internal standards to WCAG 2.2 AA. If you’re still citing WCAG 2.0 or 2.1, it’s time to update.

Testing should be treated as a multi-layered process. Automated tools are essential, but they’ll only ever catch a portion of the issues. Manual testing is non-negotiable, especially for keyboard navigation, heading structures, and ARIA usage. Assistive technology testing is where you find out if the experience actually works for people using screen readers and mobile devices. Make sure your test plan reflects the actual mix of devices and browsers your customers use. And don’t overlook the new requirements in WCAG 2.2. Many teams forget to validate drag-and-drop operations, focus appearance, or target sizes, but these are exactly the kind of issues that can create both usability headaches and legal exposure.

Procurement is another area where accessibility often falls through the cracks. If your organization buys software, you should require vendors to provide a VPAT aligned to WCAG 2.2 AA. But never stop at taking a VPAT at face value. Build contract language that sets clear consequences if a vendor fails to deliver accessible products. Otherwise, your compliance burden becomes their problem—and ultimately your risk.

Internally, treat accessibility like you would treat security or privacy. Add it to your risk registers. Audit it. Track accessibility defects in the same system as other critical issues, and assign severity based on real user impact. When leadership understands that accessibility failures carry both brand and legal risk, it becomes easier to secure the resources and budget you need.

One of the best investments you can make is real-world user testing. No automated tool can tell you whether a blind person can independently complete checkout, or whether a deaf user can follow along with your videos. Partner with disability-led usability testing groups or build your own panels. Run sessions on your critical workflows—signups, payments, forms, media playback—and bake that feedback into your design and development cycle.

Keeping an Eye on WCAG 3 Without Losing Focus

That doesn’t mean you should ignore WCAG 3 altogether. There’s value in watching where the draft is headed. If your team has bandwidth, you can begin small pilot projects in some of the emerging areas WCAG 3 highlights, such as deceptive design or algorithmic transparency. Treat those efforts as research and innovation, not as compliance requirements. Having some experience in those areas will help your organization stay ahead when WCAG 3 eventually lands.

But don’t let WCAG 3 distract you from the work you need to do now. The people who depend on accessible digital products need you to get WCAG 2.2 right today. And your legal and regulatory risk depends on it too.

The Takeaway

WCAG 3 is the future, but it’s still a moving target. The conformance model is unsettled, the testing methods aren’t finalized, and no regulator has adopted it. It’s interesting to follow and important to understand, but it’s not something you can—or should—anchor your compliance strategy on right now.

WCAG 2.2 AA, on the other hand, is clear, enforceable, and already widely recognized. It provides the structure your organization needs to stay compliant, protect against lawsuits, and actually make your products usable for people with disabilities. By doubling down on WCAG 2.2 now, you’ll be ready for whatever WCAG 3 becomes later.

So the message for compliance leaders is simple: don’t get caught up in WCAG 3 hype. Focus on mastering WCAG 2.2 AA. That’s where the real impact is today.