The September WCAG 3 Draft Proposes One Conformance Level Plus Reporting Tiers

W3C published a new WCAG 3 Working Draft on September 10, 2026, and its biggest change is the conformance model. The draft drops the three-level A, AA and AAA ladder of WCAG 2.x. In its place is one conformance level, defined as meeting every core requirement, with reporting tiers below and above it.

This piece walks through what W3C published, how the new model differs from the one agencies use today, and what the draft means by outcomes, tags and assertions. It also covers what does not change for your projects this year and how to send comments to the working group.

The short version: WCAG 3 is still an incomplete draft, and W3C says it will not be a finished standard for "a few more years." Nothing in it changes the target for client work. WCAG 2.2 Level AA remains the practical benchmark for audits, statements and reports. The conformance model is the part the working group most wants feedback on, and anyone can comment through GitHub.

What W3C published on September 10

The Accessibility Guidelines Working Group released the draft on the Recommendation track. The WCAG 3.0 Working Draft is dated 10 September 2026. The status section notes that publication as a Working Draft "does not imply endorsement by W3C."

The WAI news post for the release is brief. It points readers to the WCAG 3 Introduction for background, timeline and the list of changes. W3C last updated the introduction on September 25, 2026.

According to the WCAG 3 Introduction, the headline change in this round is simple: "The conformance approach is substantially updated." The same page describes much of the draft as exploratory. The draft itself says requirements are likely to be added, combined and removed before it is final.

W3C also published an updated WCAG 3 explainer the same day, as a draft Group Note. It is the plainest description of the new model, and several details below come from it.

WCAG 3 is also broader than WCAG 2 in scope. The introduction says it applies to web content, apps, tools, publishing and emerging technologies.

How WCAG 2.x conformance works today

Most agency accessibility work runs on WCAG 2.2, which W3C published on October 5, 2023 and updated in December 2024. Content that meets WCAG 2.2 also meets 2.1 and 2.0.

WCAG 2.x sorts its success criteria into three levels. Each level includes the one below it:

• Level A: the page meets every Level A success criterion.
• Level AA: the page meets every Level A and Level AA criterion. This is the usual target for agency work.
• Level AAA: the page meets every criterion at all three levels.

The WCAG 2.2 conformance guidance also says conformance applies to full pages only. A page with one failing criterion at a level does not conform at that level. W3C itself advises against requiring AAA across a whole site, because some content cannot meet every AAA criterion.

That structure is pass or fail per page. It says nothing about how serious a given failure is for the person who hits it. A missing focus indicator and a flashing animation are both just "fails" in a WCAG 2 report. The new draft tries to address that gap.

The WCAG 3 conformance model: one level, six tiers

The September draft defines conformance as meeting all core requirements. The explainer puts it this way: "Conformance will mean meeting all of the Core Requirements, but that is just the start."

Around that single conformance level sit reporting tiers. The introduction numbers them 1 to 6. The explainer gives them working names.

Tiers 1 and 2 are progress markers. They let a team report that a site avoids the most serious failures before it fully conforms. Tier 3 is the conformance claim itself.

Tiers 4 to 6 go beyond conformance. The introduction says the number of supplemental requirements and assertions each one needs is still to be determined. Only the top tier, as drafted, adds assertions about the organization, not just the content.

Compared with WCAG 2.x, the shift is from three nested bars to one bar with a scale around it. In WCAG 2.2, AA is the level that matters in practice and AAA is rarely required. The WCAG 3 draft makes the baseline a single claim and moves "better than baseline" into reporting.

Tags: sorting requirements by impact

The lower tiers depend on tags. Each core requirement in the draft carries one of four tags, based on what happens to a person with a disability when the requirement is not met:

• Physical harm: the failure can cause immediate physical harm.
• Risk: the failure unreasonably raises financial, medical, legal, privacy or security risk for the user.
• Barrier: the failure can stop the user from proceeding.
• Friction: the failure can hinder the user.

This is the part of the model most likely to change how audit findings read. A WCAG 2 report lists failures by criterion number. A WCAG 3 report, under this draft, would also show which failures stop people and which slow them down.

For agencies, that could help with triage. A client with limited budget could see which fixes clear the barrier tier first. It could also create pressure to stop at Tier 2 and call it progress. The working group asks directly how people would use tiers that lead up to conformance, so that concern is fair game for comments.

Outcomes: how WCAG 3 guidelines are written

WCAG 2 success criteria are written as testable statements about content. WCAG 3 guidelines are written as outcomes for users. The explainer calls them "plain-language, user-centered outcomes statements."

The draft’s first guidelines show the pattern. The captions guideline reads "Users have captions for audio content." The image alternatives guideline reads "Users have equivalent alternatives for images." Transcripts, audio descriptions and sign language follow the same form.

Each outcome is then backed by testable requirements. In the draft, those come in two kinds:

• Core requirements count toward conformance and carry the four tags.
• Supplemental requirements count toward the tiers above conformance.

Requirements use "applies when" and "except when" wording to set their scope. Recommended practices and technology-specific methods sit alongside them as supporting material.

If your team already writes remediation tickets as user impact ("screen reader users cannot submit the form"), the outcome format will feel familiar. Our explainer on making PDFs meet WCAG uses the WCAG 2.2 criteria today, and it will stay the right reference until WCAG 3 is final.

Assertions: claims about process, not pages

Assertions are the newest idea for most practitioners. The explainer defines one as "an attributable and documented statement of fact regarding procedures practiced in the development and maintenance of the content or product to improve accessibility."

In plain terms, an assertion is a signed claim about how the work gets done. The draft’s examples include having a style guide that covers captions, running usability testing with people who need transcripts, and having authors review captions. Assertions need a named role or organization, a date and documentation behind them.

Assertions do not replace core requirements. Under this draft, they only count toward the tiers above conformance. That matters for agencies because assertions describe practices a client owns. Training, style guides and user testing continue after launch, and an agency cannot make those claims for a client it no longer works with.

A second model still under discussion

The draft is not the only option in play. The explainer describes an alternative the working group is considering, which scores core requirements by percentage and weights them by tag. The explainer states that the scoring approach is not included in the WCAG 3 draft itself.

The introduction’s review questions ask readers to weigh the approaches. It asks "What pros and cons do you see for each approach?" and whether the new model improves on the conformance approach in earlier drafts.

Treat the tier names, the tier count and the tagging as proposals. The introduction warns that much of the draft "will change substantially." A new round of drafts could rename or restructure any of it.

What does not change for agencies today

For client work in 2026, the target is the same as it was in August. WCAG 2.2 Level AA remains the practical benchmark. The introduction says so in its own words: "The best way to prepare for WCAG 3 in the future, is to meet WCAG 2.2 success criteria now."

The draft also gives a sense of how much carries over. It states that content conforming to WCAG 2.2 Level A and AA "is expected to meet most of the minimum conformance level of this new standard." It adds that WCAG 3 has additional tests and different scoring, so more work will be needed for full conformance.

W3C also says WCAG 2 will not be deprecated for several years after WCAG 3 is finalized. Many legal and procurement requirements reference WCAG 2.x, and this post does not cover them.

What the draft means for audit reports and ACRs

Audit reports will keep citing WCAG 2.2 success criteria for the foreseeable future. So will the tools behind them. The scanners we covered, including Siteimprove’s crawler, Silktide and Deque’s axe engine, report against WCAG 2 criteria. Their coverage figures are stated as a share of WCAG 2 issues or criteria.

Accessibility Conformance Reports work the same way. According to ITI’s VPAT page, the current VPAT 2.5Rev template maps to WCAG 2.x, and its WCAG edition references WCAG 2.2. As of September 2026, that page does not mention WCAG 3.

Two parts of the draft are worth watching for reporting. The tags could give audit reports a shared way to rank severity. Assertions could also give a formal place to the training and program work that firms such as Level Access sell alongside audits and VPAT production. Neither is settled.

Vendors may start adding "WCAG 3 ready" language to product pages. Given the draft status, ask what that phrase maps to. Our profile of AudioEye covers why checking vendor claims against primary sources matters in this category.

How to comment on the WCAG 3 draft

The working group asks for comments on the conformance model in particular. The introduction lists three review questions:

• “Does this improve upon the conformance approach in previous drafts?”
• “What pros and cons do you see for each approach?”
• “How would you leverage reporting tiers leading to conformance or above conformance?”

The main channel is GitHub. Open a new issue in the WCAG 3 GitHub repository. A GitHub account is free. For people who cannot use GitHub, the introduction lists a public comments mailing list in its commenting section.

Neither the draft nor the introduction states a comment deadline. Comments on this draft feed the next one, so earlier is more useful than later.

Useful comments from agencies are specific. Describe how you report to clients today, where a tier would help or confuse a nonprofit board, and which assertions a small organization could realistically keep up. Agencies that caption client video, a topic we touched on in our captioning model retirement coverage, may have practical input on the media guidelines too.

When WCAG 3 might be finished

W3C does not give a date. The introduction says WCAG 3 is not expected to be a completed standard for "a few more years."

The working group keeps a public schedule on GitHub, last edited in April 2026. It plans more Working Drafts through 2027 and targets a Candidate Recommendation snapshot in the fourth quarter of 2027. The same page notes that final Recommendation has historically come about two years after that stage. Treat those dates as plans, not commitments.

Even after WCAG 3 is final, WCAG 2 is not going away quickly. W3C says WCAG 2 will not be deprecated for several years after that point. For agencies, that means WCAG 2.2 AA work done now keeps its value for a long time.

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