Everyone is getting ready for WCAG 2.2. Two thirds of Europe's biggest sites still fail 2.1 Level A.

The next version of the European accessibility standard is scheduled for citation on 30 November 2026. EN 301 549 V4.1.1 swaps WCAG 2.1 for WCAG 2.2, and six new success criteria arrive at levels A and AA. There is a small industry of readiness checklists for it already. So I measured what the current version looks like first. The answer is that the deadline people are preparing for is not the one they have missed. I scanned the most-visited websites on EU country domains and counted which clauses of EN 301 549 they fail today, under the version cited right now. Not the one arriving. The one in force since before the European Accessibility Act deadline passed in June 2025. Sixty-four per cent fail clause 9.4.1.2, Name, Role, Value. It is Level A, the lowest bar the standard has, and it has been in every version of WCAG since 2008. Here is the full picture, and then the reasons to distrust parts of it. What was measured Clause Criterion Level Sites failing 9.4.1.2 Name, Role, Value A 96 of 149 (64%) 9.1.4.3 Contrast (Minimum) AA 66 of 149 (44%) 9.2.4.4 Link Purpose (In Context) A 53 of 149 (36%) 9.2.5.8 Target Size (Minimum) AA 51 of 149 (34%) 9.1.1.1 Non-text Content A 35 of 149 (23%) 9.1.3.1 Info and Relationships A 27 of 149 (18%) Target size is the odd one out: it is a WCAG 2.2 criterion and not currently required. It is in the table because it is the only one of the six arriving in V4.1.1 that the rule engine used here has a check for, which is a point I will come back to. Thirty-two sites of the 149, about one in five, failed nothing that automated testing can detect. That is not the same as passing. Two of those rows are not independent. The rule that most often breaks Name, Role, Value is a link with no accessible name, and the same defect also fails Link Purpose. One missing label lands in two rows of that table. I am pointing this out because a table of six numbers implies six problems, and some of them are the same problem counted twice under different cla