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Website Accessibility Checklist for Small Businesses (WCAG 2.2)

A website accessibility checklist for small businesses: what the ADA expects, what's new in WCAG 2.2, and 13 checks you can run yourself with free tools.

By Angel Lord, Web Design Lead9 min read

Man wearing dark glasses and over-ear headphones reading a braille sheet with one hand at a desk with a keyboard and monitor

Maybe a letter arrived saying your website “isn’t ADA compliant,” with an offer to fix it for a monthly fee. Maybe a customer told you they couldn’t book online with a screen reader. Or you just want to get it right before it becomes a problem.

This website accessibility checklist is for that moment. It covers what the law expects of a small business as of October 2026, what changed in WCAG 2.2, and 13 checks you can run yourself in an afternoon with a keyboard and free tools. It also explains why the widget in that letter won’t fix the problem.

We’re a web team, not a law firm, so treat the legal section as background and talk to an attorney about your own situation.

Does the ADA apply to my small business website?

Short answer: If your business is open to the public, the Justice Department’s position is that the ADA covers what you offer online, too. There’s no federal regulation with a technical web standard for private businesses, so the DOJ points to WCAG as a helpful guide and leaves you flexibility in how you comply.

For ADA website compliance, a small business starts from the DOJ’s web accessibility guidance, published March 18, 2022. The guidance says Title III’s requirements apply to all the goods, services, privileges or activities a public accommodation offers, including those offered on the web. Its examples of barriers are refreshingly ordinary: poor color contrast, color used as the only way to convey information, missing alt text, videos without captions, forms without labels or error messages, and navigation that only works with a mouse.

The lawsuits are real and rising again. Seyfarth Shaw, which tracks federal ADA filings, counted 3,117 website accessibility lawsuits in federal court in 2025, up 27% from 2,452 in 2024. They made up 36% of all 8,667 ADA Title III federal cases. New York (1,021) and Florida (961) led, and those counts leave out state-court suits and demand letters, which the firm says still come in significant numbers.

What did the DOJ’s Title II rule change, and was it delayed?

Short answer: The 2024 rule requires state and local governments to meet WCAG 2.1 Level AA. In April 2026 the DOJ pushed the deadlines back a year: governments serving 50,000 or more people now have until April 26, 2027, and smaller ones and special districts until April 26, 2028.

The original deadlines were April 24, 2026 and April 26, 2027. An interim final rule issued on April 20, 2026 moved both, as the Pacific ADA Center summarizes, and the DOJ’s fact sheet now shows the new dates. The technical standard didn’t change.

Why should a private business care? Two reasons. If you build, host or run anything for a city, county, school district or transit agency, the fact sheet says governments must make sure contractors who provide services on their behalf follow Title II. And WCAG 2.1 AA is now written into a federal rule, which makes it the obvious benchmark to build toward.

What’s new in WCAG 2.2?

Short answer: WCAG 2.2 became a W3C Recommendation on October 5, 2023. It adds nine success criteria, six of them at Level A or AA, and removes 4.1.1 Parsing. Everything else from 2.0 and 2.1 is essentially the same.

That summary is from the W3C’s own What’s New in WCAG 2.2. Most businesses aim for Level AA, so these are the six new criteria that matter:

Criterion Level What it means in practice
2.4.11 Focus Not Obscured AA Sticky headers, chat bubbles and cookie banners can’t completely hide the focused item
2.5.7 Dragging Movements AA Anything done by dragging also works with a single tap or click
2.5.8 Target Size AA Buttons and links are at least 24 by 24 CSS pixels, or well spaced
3.2.6 Consistent Help A Contact details or help links appear in the same place on each page
3.3.7 Redundant Entry A Don’t make people retype details they already gave in the same process
3.3.8 Accessible Authentication AA Logins don’t depend on memory puzzles; allow pasting and password managers

The other three new criteria are at Level AAA, the strictest tier.

Woman in glasses and an olive blazer typing on a laptop at a white desk while seated in a wheelchair, seen from above

The website accessibility checklist

Here are the checks worth running on your home page, your main service or product page, your contact or booking form and your checkout if you have one. Each maps to a WCAG 2.2 success criterion, so you can tell a developer exactly what’s failing.

Check How to test WCAG
Everything works by keyboard Tab through the page; use Enter, Space, arrows, Esc 2.1.1 (A)
Focus is always visible Watch for a clear outline on every stop 2.4.7 (AA)
Focus isn’t hidden Tab past sticky headers, banners and chat 2.4.11 (AA)
Text contrast At least 4.5:1, or 3:1 for large text 1.4.3 (AA)
Icon and border contrast Buttons, icons, field borders at 3:1 1.4.11 (AA)
Images have alt text Run WAVE or axe; read each alt 1.1.1 (A)
Headings make an outline One H1, then H2s and H3s in order 1.3.1 (A)
Form fields have labels Click each label; it should focus its field 3.3.2 (A)
Errors are described in text Submit the form empty 3.3.1 (A)
Videos have captions Play each video with sound off 1.2.2 (A)
Tap targets are big enough 24 by 24 CSS px, or spaced apart 2.5.8 (AA)
Zoom and reflow work 200% text; 400% zoom at 1280 px 1.4.4, 1.4.10 (AA)
Page language is set Check the lang attribute 3.1.1 (A)

The short criteria names are ours; the requirements are from the WCAG 2.2 standard itself.

How to run the checks yourself

You need a laptop with Chrome, Edge or Firefox. Allow an afternoon for four key pages; none of it costs anything.

Step 1: Put the mouse away

Click in the browser’s address bar, then press Tab repeatedly. Every link, button and field should get a visible outline, in an order that follows the page. Open the menu, the booking widget and any pop-up with Enter or Space, and close them with Esc. If you get stuck somewhere and Tab won’t move you on, that’s a keyboard trap and a serious failure.

Step 2: Watch what covers the focus

Keep tabbing down the page with your cookie banner, sticky header and chat button showing. If the focused link disappears behind any of them, that fails 2.4.11. A cookie banner pinned to the bottom of the screen can do exactly this; our guide on whether you need a cookie banner covers the alternatives.

Step 3: Zoom in

Press Ctrl and + (Cmd and + on a Mac) until the browser shows 200%: all the text should still be readable, with nothing cut off or overlapping. Then, with the window about 1280 px wide, go to 400%. The W3C’s reflow guidance says that’s equivalent to a 320 px wide screen, and the page should scroll in one direction only, apart from things like data tables and maps.

Step 4: Check contrast and targets

WAVE and axe both flag low-contrast text. For buttons, icons and form borders, pick the colors with an eyedropper and test them in a free contrast checker such as WebAIM’s against the 3:1 rule. For tap targets, the W3C’s target size guidance allows smaller targets if a 24 px circle centered on each one doesn’t overlap its neighbor; links inside sentences are exempt.

Step 5: Break your own forms

Submit the contact or booking form empty, then with a bad email address. Each error should say in words what’s wrong and which field, not just turn a border red. Click each field’s label: if the cursor jumps into the field, the label is properly connected.

Step 6: Listen to one page

Turn on the screen reader built into your device (VoiceOver on a Mac or iPhone, Narrator on Windows, TalkBack on Android) and listen to your home page. You’ll hear quickly whether images make sense, buttons have names and headings tell the story.

Tip: Fix the paths that make you money first: the phone number, the contact or booking form, the menu and the checkout. A perfect blog archive doesn’t matter if someone can’t request a quote.

Which free tools check website accessibility?

Short answer: WAVE, axe DevTools and Lighthouse are free and good at catching common errors. None of them can tell you a site is accessible, because many problems need a person to judge.

What each one does:

  • WAVE from WebAIM runs online or as a browser extension for Chrome, Firefox and Edge, and marks problems directly on the page. WebAIM describes it as a tool to facilitate human evaluation.
  • axe DevTools from Deque has a free extension for Chrome, Edge and Firefox. The free version runs automated tests one page at a time; guided manual tests are a paid feature.
  • Lighthouse, built into Chrome DevTools, gives an accessibility score that is a weighted average of pass/fail audits. Its manual checks, such as tab order and focus traps, aren’t scored at all.

How much do automated tools catch? Deque’s own 2021 study of more than 2,000 audits found that automated testing covered about 57% of issues by volume. That’s vendor data on its own tools, but even taken at face value it leaves a large share for people to find. The W3C’s Easy Checks puts it plainly: a page “could seem to pass these checks, yet still have significant accessibility barriers.”

The common failures are basic. In WebAIM’s 2026 analysis of the top million home pages, 95.9% had detectable WCAG failures, an average of 56.1 errors a page. The most common were low-contrast text (83.9% of pages), missing alt text (53.1%), missing form labels (51%), empty links (46.3%) and empty buttons (30.6%).

Our own site scores 100 in Lighthouse accessibility, and we test pages with axe as well. We treat that as the floor, not the finish line, because neither tool can tell you whether a person can actually complete a task.

Do accessibility overlay widgets make a website compliant?

Short answer: No tool can honestly promise that. In April 2025 the FTC ordered accessiBe, the maker of an accessibility widget, to pay $1 million over claims that its automated tool could make any website WCAG-compliant.

According to the FTC’s announcement on April 22, 2025, the agency alleged those claims were false, misleading or unsubstantiated because the tool didn’t make all customer websites compliant. It also alleged that the company presented articles and reviews as independent without disclosing its ties to the authors. The final order bars the company from claiming its automated products can make any website WCAG-compliant without evidence to support it.

Our take: If a widget can’t fix a form that has no labels or a checkout that traps the keyboard, it hasn’t fixed your site. Spend the overlay budget on fixing the theme and templates, which fixes every page built from them.

What should you fix first?

Short answer: Fix what blocks a customer from contacting you or paying you, then the site-wide template problems, then individual pages. Template fixes are the best value because one change repairs every page that uses it.

A sensible order for most small business sites:

  1. Forms and checkout: labels, error messages, keyboard access and logins that allow pasting.
  2. Header, menu and footer: keyboard access, visible focus, contrast and consistent contact details.
  3. Theme colors and buttons: fix contrast once in the theme settings instead of page by page.
  4. Images and video: alt text that describes the purpose of each image, captions on every video.
  5. Content structure: headings in order and links that make sense out of context (“Book a service call,” not “Click here”).

When the main fixes are done, publish an accessibility statement with a way to report problems. The W3C has a free statement generator and suggests listing known limitations honestly, in plain language.

What to do this week

  1. Do the keyboard test (Steps 1 and 2) on your home page and your contact or booking form.
  2. Run WAVE or axe on the same pages and fix the contrast, alt text and label errors they flag.
  3. Check that your cookie banner, sticky header and chat button never hide the focused item.
  4. Turn down any widget that promises instant ADA compliance.
  5. Publish a short accessibility statement with an email address or phone number for reporting problems.

Accessibility work is cheapest when it’s built in, which is why it shows up as a line item in our guide to what a small business website costs. It also overlaps with speed; see how we got our site to 100 in Lighthouse. If you’d like help fixing what you find, talk to our web development team or ask about IT consulting.

Frequently asked questions

Is WCAG a law?

No. WCAG is a set of guidelines published by the W3C. It becomes a legal requirement where a rule adopts it, as the Justice Department's 2024 rule did with WCAG 2.1 AA for state and local governments. For private businesses, the Justice Department's guidance points to WCAG as a helpful reference rather than a mandated standard.

Should I aim for WCAG 2.1 or WCAG 2.2?

Aim for WCAG 2.2 Level AA. The W3C says the 2.0 and 2.1 success criteria are essentially the same in 2.2, apart from the removed 4.1.1 Parsing, so meeting 2.2 AA also covers what 2.1 AA asks for, plus six more A and AA criteria.

Does a 100 Lighthouse accessibility score mean my site is compliant?

No. Lighthouse's accessibility score is a weighted average of automated pass/fail audits, and its manual checks, such as logical tab order and focus traps, don't count toward the score. A 100 means the automated checks passed, which is a good floor but not proof that people can use the site.

Do PDFs and documents on my website need to be accessible?

If a PDF is the only way to get something, such as a menu, price list or application form, treat it like a web page: give it real text, headings and form fields, or publish the same content as an accessible web page. A scanned image of a document is unreadable to a screen reader.

How often should I test my website's accessibility?

Run the quick checks whenever you change a template, add a form, install a widget or launch a new section, and do a full pass once or twice a year. New plugins, chat widgets and cookie banners are common ways a site that passed last year starts failing.

Sources

Every figure in this article comes from these pages; we checked each one on the date shown.

  1. Guidance on Web Accessibility and the ADA. U.S. Department of Justice, ADA.gov. Checked .
  2. Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments. U.S. Department of Justice, ADA.gov. Checked .
  3. DOJ delays ADA Title II Web and Mobile App Accessibility Rule compliance deadlines. Pacific ADA Center. Checked .
  4. Federal Court Website Accessibility Lawsuit Filings Bounce Back in 2025. Seyfarth Shaw, ADA Title III blog. Checked .
  5. What's New in WCAG 2.2. W3C Web Accessibility Initiative. Checked .
  6. Web Content Accessibility Guidelines (WCAG) 2.2. W3C. Checked .
  7. Understanding Success Criterion 1.4.10: Reflow. W3C Web Accessibility Initiative. Checked .
  8. Understanding Success Criterion 2.5.8: Target Size (Minimum). W3C Web Accessibility Initiative. Checked .
  9. Easy Checks: A First Review of Web Accessibility. W3C Web Accessibility Initiative. Checked .
  10. The WebAIM Million (2026). WebAIM. Checked .
  11. WAVE Web Accessibility Evaluation Tools. WebAIM. Checked .
  12. Axe DevTools browser extensions. Deque Systems. Checked .
  13. Automated testing study identifies 57 percent of digital accessibility issues. Deque Systems. Checked .
  14. Lighthouse accessibility scoring. Chrome for Developers. Checked .
  15. FTC Approves Final Order Requiring accessiBe to pay $1 Million. Federal Trade Commission. Checked .
  16. Developing an Accessibility Statement. W3C Web Accessibility Initiative. Checked .

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