Most teams treat WCAG (the Web Content Accessibility Guidelines) as a tick-box exercise their developers handle. That underestimates two things at once: how much of the standard maps onto real customer harm, and how directly UK law and FCA guidance now reference it.
What WCAG actually is
WCAG is published by the W3C and structured around four principles - perceivable, operable, understandable, robust. Each principle has success criteria graded A (basic), AA (the standard most regulations require) and AAA (the highest bar, rarely required in full).
The current published version is WCAG 2.2, released in October 2023. It adds nine new criteria covering focus appearance, dragging movements, target size, consistent help, accessible authentication and a handful of cognitive accessibility wins. Anything that complies with 2.2 also complies with 2.1 and 2.0.
It is a legal requirement for the UK public sector
Since September 2018, the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 have required UK public sector websites and apps to meet WCAG 2.1 AA, with documented accessibility statements published. WCAG 2.2 became the standard public sector teams are expected to design to from late 2024 onward.
The official UK guidance is on GOV.UK:
- Accessibility requirements for public sector websites and apps
- Understanding WCAG (GOV.UK Service Manual)
- Sample accessibility statement
Non-public-sector firms are not yet required by UK statute to meet WCAG, but the Equality Act 2010 already prohibits indirect discrimination against disabled customers - and a service that excludes disabled customers because of an accessibility failure is the textbook definition.
The disabilities WCAG covers
The standard is structured by what a person needs to perceive, operate and understand a digital service. The disability groups it directly addresses include:
- Visual - blindness, low vision, colour-vision deficiency. Affected by colour contrast, zoom support, screen-reader compatibility, alternative text for images.
- Auditory - deafness and hearing loss. Affected by captions on video, transcripts, visual alternatives to audio cues.
- Motor - limited dexterity, tremor, paralysis, missing limbs. Affected by keyboard navigation, target size, drag-free alternatives, predictable interaction.
- Cognitive - dyslexia, learning disabilities, ADHD, autism, memory and processing differences, mental-health conditions. Affected by clear language, predictable layout, consistent help, error prevention, minimum reading load.
- Speech - difficulty with voice input or voice-only interfaces. Affected by text alternatives to voice-activated features.
- Situational - bright sunlight, noisy environment, broken arm, holding a baby. The same accommodations help anyone whose context temporarily limits how they interact with a service.
Why this matters for Consumer Duty
The FCA's definition of a vulnerable customer covers four overlapping drivers: health, life events, resilience and capability. If you map those against the WCAG disability groups, the overlap is large:
- Health includes physical disabilities, sensory disabilities, mental-health conditions and cognitive impairments - every WCAG group above sits inside it.
- Capability includes low literacy, low numeracy and low digital confidence - the cognitive WCAG criteria (clear language, consistent help, error prevention) directly address this.
- Life events can produce situational disability - a recent bereavement, a new caring responsibility, the day after a hospital procedure.
- Resilience sits alongside the other three; an accessibility barrier hits hardest when a customer has no slack to absorb it.
Put another way: the customers most likely to be harmed by a Consumer Duty failure are largely the same customers WCAG was written to protect. Documented WCAG conformance is therefore one of the most defensible forms of Consumer Duty evidence a firm can produce.
What WCAG 3.0 changes - and why cognitive accessibility is the focus
WCAG 3.0 (Silver) is the next major version, currently in working draft at the W3C. It is a deliberate departure from 2.x: the binary pass/fail criteria are being replaced by a scored model that recognises partial conformance and weights tasks by how much they affect real users. Crucially, it expands cognitive accessibility into a first-class concern rather than the afterthought it sometimes felt in 2.x.
Why the shift? Two reasons. First, cognitive disabilities are vastly under-served by 2.x - many criteria are easier to meet for visual or motor disability than for, say, working-memory limitations. Second, the digital interfaces customers face are getting more cognitively demanding, not less, in part because AI-generated layouts increasingly stack dense imagery, animation, dynamic copy, modal upon modal, and AI-summary panels alongside the original content. A page that passes 2.2 to the letter can still overwhelm a customer with a working-memory limitation, an attention-related condition or a recent head injury.
3.0's direction of travel is to score that overwhelm explicitly. Firms that get ahead of cognitive accessibility now will not be retro-fitting it later.
How UXDuty fits in
UXDuty runs the WCAG 2.2 ruleset on every page in a journey, covering the technical AA criteria - contrast, alt text, labels, headings, keyboard reachability and the rest.
On top of Axe, UXDuty runs an AI heuristic pass that looks specifically for the kind of cognitive overwhelm WCAG 2.2 only partly catches and WCAG 3.0 will score directly. That includes:
- Pages with too many simultaneous calls-to-action competing for attention.
- Dense, jargon-heavy paragraphs at reading levels above the customer base.
- Animated, auto-playing or dynamically-changing content that interrupts the reading task.
- Overlay-on-overlay patterns (cookie banner + chat widget + promotional modal + AI summary panel) that fight for the same screen real estate.
- Important information buried below interruptive elements.
Each issue is reported in plain language with a screenshot, a Consumer Duty risk band, and a specific recommendation - what to remove, simplify or restructure. The PDF report you can hand to a regulator covers both the WCAG 2.2 technical detail and the cognitive-overwhelm findings on the same page.
The bottom line
For UK public sector teams, WCAG 2.2 AA is the line. Below it you are out of compliance with the 2018 Regulations.
For financial firms, WCAG conformance is not yet a hard line in statute but it is the most reliable evidence base for Consumer Duty's vulnerable-customer expectations - and as WCAG 3.0's cognitive focus arrives, firms that have already built the evidence loop will spend a lot less catching up.
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