Web Accessibility (WCAG) and Cookie Banners: The 2026 Compliance Checklist

The European Accessibility Act (EAA) came into force on June 28, 2025, establishing mandatory accessibility standards for key digital products and services across the EU, including e-commerce, banking, telecoms, transport, and media. The EEA requires websites to make services accessible for people with disabilities.

Both the global WCAG and the European EEA set requirements for cookie banners.

In this guide, you’ll learn what the WCAG 2.2 requirements for Cookie Consent banners are and how to implement these changes on your website.

What IS WCAG and the Main Differences Between WCAG 2.1 vs. WCAG 2.2

WCAG stands for Web Content Accessibility Guidelines. WCAG are technical guidelines for improving the accessibility of websites, web content, and web applications on desktop computers, laptops, tablets, and mobile devices for people with visual, auditory, motor, and cognitive disabilities.

Even if WCAG itself isn’t a law, and WCEG guidelines are not mandatory, it has become the technical standard that regulators or courts rely on when deciding whether a website is accessible. That includes cookie banners, consent options, and preference buttons.

WCAG 2.1 vs. WCAG 2.2: What Changed?

WCAG 2.2 doesn’t replace 2.1, it expands the guidelines, adding the requirements for website or web content usability, not just technical accessibility.

Key differences that matter for cookie banners:

Stronger visibility requirements.
Keyboard users must clearly see their position on the banner when navigating consent buttons.
More attention to cognitive accessibility: requirements for cleared labeling, predictable behavior, and reduced user confusion.
Increased target size requirements: “Accept” and “Reject” buttons must be easy to tap (for mobile applications).
Requirements for easier management of dragging, motion, and interaction (relevant for animated or sliding consent panels).

The European Accessibility Act

The European Accessibility Act (EAA) came into law on June 28, 2025. It regulates most digital services in the European Union and also requires websites and mobile apps to be accessible to people with disabilities.

To reach the EAA compliance, cookie banners must follow the POUR principles (Perceivable, Operable, Understandable, Robust), usually set by WCAG 2.2 Level AA standards.

Why Should My Cookie Banner Be WCAG 2.2 Compliant?

In 2026, accessibility issues in cookie banners are no longer seen as UX problems. They are treated as compliance risks and could have other disadvantages for your website.

Your Cookie Banner should be WCAG 2.2 compliant for the following reasons:

Legal requirements
Since the European Accessibility Act took effect in 2025, your Cookie Banner should adhere to the WCAG 2.2 accessibility standards. Non-compliance with the WCAG 2.2 standards could lead to penalties, similar to these observed with the enforcement of the GDPR.
Increased engagement
Accessible cookie banners greatly improve the overall online experience for users with disabilities and increase engagement with your website. Implementing the WCAG 2.2 standards gives your business a competitive advantage. The world’s population is rapidly aging, so the demand for accessible cookie banners will continue to grow.
Building user trust
Users are concerned about their online privacy. According to studies by Thales, 70% of consumers say they would immediately stop doing business with a company that uses their data without permission. If disabled users can’t access the Cookie Banner, they will not become your business‘ customers.

WCAG, GDPR, and ePrivacy: Where the Rules Intersect

GDPR and the eprivacy directive are European laws that focus on lawful consent. WCAG focuses on equal access to a website. However, they overlap more than most developers expect.

Here’s where the requirements of WCAG, GDPR, and eprivacy overlap:

GDPR requires consent to be freely given, informed, and unambiguous. If a disabled user can’t access all options of a Cookie Banner, consent may be invalid.
eprivacy governs how cookies should be delivered and accepted. Accessibility barriers block the access of all options of a cookie banner, consent may be invalid.
WCAG defines whether the interface enables equal choices for people with disabilities to interact with the cookie banner and give valid Cookie Consent.

Regulators often view accessibility as a precondition for valid consent. If your cookie banner is not compliant with the WCAG 2.2 standards, your business could be fined for non-compliance with the GDPR.

WCAG Principles Applied to Cookie Banners

To meet WCAG 2.2 standards, your cookie banner should follow the POUR principles:

Perceivable

Users must be able to see or hear the information present on a cookie banner.

Ensure:

Proper color contrast for text and buttons.
Screen-readable labels and headings.
No important information is hidden in visual-only elements.

For example, a minimum color contrast should be met of 4.5:1.

Operable

Users must be able to interact with the banner:

Users should be able to navigate the cookie banner and make selections using only the keyboard.
Use logical focus order.
Avoid traps that lock users inside the banner.

Understandable

Users should easily understand what they agree to:

Use plain and simple language, avoiding jargon.
Make a clear distinction between “Accept,” “Reject,” and “Manage preferences”.
Implement predictable behavior when toggles are changed.

Robust

The banner must work across all platforms and technologies.

Ensure your cookie banner’s properties:

Functional across all platforms, browsers, and devices.
Compatible with screen readers.
Does not rely on unsupported or weak scripts.

The 2026 WCAG Cookie Banner Compliance Checklist

A WCAG-aligned cookie banner in 2025 should meet the following best practices:

Position the cookie banner early in the HTML structure.
Write the cookie banner text in plain language
Ensure the banner doesn’t obscure content or focusable elements.
Make the cookie banner fully accessible by keyboard.
Make sure all buttons can be reached and used via keyboard.
Use clear, descriptive button labels.
Implement a visible focus indicator on every interactive element.
Ensure the cookie banner can be zoomed 200%.
Use equal visual weight for “Accept” and “Reject” options.
Use sufficient color contrast for text and controls.
Make preference options accessible without time limits.
Use more than color to show links and active states.
No auto-dismissal without user action.

All these recommendations are important. If even one of these fails, cookie banner accessibility and even potentially consent validity comes into question.

Common WCAG Failures in Cookie Banners

Despite increased awareness, some problems still appear when a cookie banner does not follow the POUR principles.

Common WCAG failures in cookie banners include:

Contrast failure
Banners often use light grey text on a white background or white text on a light blue button.
Requirement: Use a minimum contrast ratio of 4.5:1 for body text and 3:1 for large text/icons.
Undistinguishable buttons
Using only color to distinguish "Accept" (green) from "Reject" (red).
Requirement: Use text labels or distinct shapes so colorblind users can distinguish the buttons.
Missing non-text content
Missing alt text on company logos or icons within the banner.
Requirement: All functional images, including a "Close" icon, must have a descriptive text alternative for screen readers.
Banner navigation problems
Many banners can’t be reached using the Tab key.
Requirement: Make sure the banner can be navigated without a mouse, using only the Tab, Enter, and Space keys.
Hidden reject options
The reject options must be easy to find.
Requirement: Don’t burry reject options behind multiple clicks.
Target Size
Banner buttons are often too small or too close together for users with motor impairments.
Requirement: Use interactive targets that are at least 24x24 CSS pixels (or have sufficient spacing).
Language of page
Sometimes banners do not programmatically declare their language (e.g., <div lang="de">).
Requirement: Screen readers must know which language to use for text-to-speech synthesis.
Wrong banner coding
If a banner is coded as a simple <div> instead of a dialog, screen readers will not recognize the banner as an overlay that requires immediate attention.
Requirement: Use ARIA roles like role="dialog" and aria-modal="true" so screen readers recognize the banner and display it correctly.

As a website owner, you can’t control everything. You can manage the content and the cookie banner design options, such as choosing readable colors, writing a clear cookie notice, or placing the banner on the right position of the page.

Technical accessibility features like keyboard navigation, focus management, and screen reader announcements should come from your Consent Management Platform (CMP).

Testing Accessibility for Cookie Consent

Test your cookie banner’s accessibility practically- theoretical work is not enough.

Test at least these key features:

Keyboard-only testing Test whether you can open, navigate, and close the banner without a mouse.
Screen reader testing Test whether banner buttons, headings, and toggles make sense when read aloud.
Contrast and focus testing Test whether interactive elements are clearly visible and easy to understand.

Automated tools can help, but don’t rely on them. You should test manually how banner logic, clarity, and real user flow work for a real user.

Choosing an Accessible Cookie Consent Platform

Not all Cookie Consent platforms are built with accessibility in mind.

Choose the right CMP that complies with the WCAG 2.2 requirements.

CookieScript CMP is a professional CMP that can help you reach WCAG compliance. It has the following features:

WCAG 2.2-compliant cookie banner
Integrations with CMS platforms like WordPress, Shopify, Joomla, etc.
Cookie banner customization
High contrast ratio for cookie banners
Google Consent Mode v2 integration
IAB TCF v2.2 integration
Google Tag Manager integration
Certification by Google
CookieScript API
Cookie Scanner
Consent recordings
Third-party cookie blocking
Geo-targeting
Local storage and session storage scanning

Read more about how to compare and select the right CMP for your website.

Frequently Asked Questions

What is WCAG and does it apply to cookie banners?

WCAG (Web Content Accessibility Guidelines) are technical guidelines for improving the accessibility of websites for people with disabilities. It applies to all interactive elements of a website, including cookie banners. Because cookie banners require user interaction, they must meet accessibility requirements. Use CookieScript CMP to create a WCAG-compliant cookie banner.

Is WCAG 2.2 legally required for cookie banners?

WCAG itself is not a law, but it is widely used by regulators and courts to assess a website’s accessibility. In practice, WCAG 2.2 has become the expected standard in 2025 when evaluating whether a cookie banner allows all users, including disabled ones, to give valid, informed consent.

How is cookie banner accessibility related to GDPR compliance?

GDPR requires consent to be freely given, informed, and unambiguous. If users with visual disabilities can’t access a cookie banner, for example, with a keyboard or screen reader, they may be unable to refuse or manage cookies. In those cases, consent would be considered invalid, even if the banner appears compliant on the website. Thus, to reach GDPR compliance, you must have a WCAG-compliant cookie banner, accessible to all users.

How do WCAG, GDPR, and eprivacy work together?

GDPR and the ePrivacy directive regulate the requirement for consent and how to obtain it. WCAG defines whether users with disabilities can actually access and use the consent interface. If a cookie banner fails WCAG requirements, it can undermine GDPR and ePrivacy compliance by preventing equal access to consent choices. Use CookieScript CMP to create a WCAG-compliant cookie banner.

What are the most common WCAG failures in cookie banners?

Common accessibility issues include hidden reject buttons, poor color contrast, missing focus indicators, keyboard traps, tiny toggle switches, and missing language and non-text content. These issues often prevent users with disabilities from making a real consent choice that could lead to non-compliance with privacy laws. Use CookieScript CMP, which supports WCAG compliance.

How to find a WCAG-compliant Cookie Consent platform?

An accessible CMP should offer keyboard navigation, screen-reader compatibility, equal consent options, WCAG 2.2 alignment, and regular updates. CookieScript CMP is a WCAG-compliant CMP, offering features such as banner design configuration or high contrast ratio for cookie banners.

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