An Official Journal citation due late 2026 turns WCAG 2.2 into an EAA obligation

Citation is the trigger, and the trigger has already moved. Estimates shifted by weeks while the standard worked through review, and they now sit between 30 November and 16 December 2026 ^[5]. That is a window of sixteen days ^[1]. From the late end of the window to the year boundary is fifteen more ^[2]. One more slip of the size already observed and the obligation lands in 2027, which the only available precedent supports: V3.2.1 was published in March 2021 and cited about five months later ^[6].

Of the six new clause 9 criteria, the expensive one to find is focus visibility. A focused element must not be entirely hidden behind sticky headers, cookie bars or floating chat bubbles ^[11]. The dev.to author calls this the criterion most likely to fail on a modern site, because sticky elements are everywhere and almost nobody tabs through their own page ^[11]. The failure lives in page composition rather than in any single component, so auditing your component library will not surface it. You find it by tabbing every template.

Two of the six are cheap for most teams. A help mechanism has to appear in the same relative order across pages, which sites with a stable header already satisfy; the ones that fail have moved help into a hamburger on some templates and not others ^[9]. Dragging needs a single-pointer alternative that is not a drag, so sliders, kanban boards, reorderable lists and map panning acquire buttons ^[12].

Target size is where old advice misleads. WCAG 2.2 asks for 24 by 24 CSS pixels, with exceptions for inline links in text and for targets with enough spacing around them ^[13]. WCAG 2.1 did have a target size criterion, 2.5.5, but it was Level AAA at 44 pixels, so it was never in scope for EAA conformance ^[14]. A 24 pixel square is about 30 percent of the area of a 44 pixel square, 576 over 1936 ^[3]. If a consultant sold you 44 as the legal floor, they sold you a AAA criterion.

The bigger change sits outside clauses 9 to 11. Clause 6 broadens from two-way voice to real-time bidirectional communication, formally taking in Total Conversation: voice, real-time text and video ^[18]. That is a feature list rather than a remediation list, and it needs product decisions well before a citation date that nobody on your side controls. If your calling stack is voice-only, the exact day matters far more to you than any of the clause 9 deltas.