# What Changed in the WCAG 3 September 2026 Draft: Levels Move from Conformance to Reporting

> WCAG 3 September 2026 Working Draft explained: one conformance line, Bronze/Silver/Gold as reporting tiers, and 216 requirements counted by hand.

**Published:** 2026-09-10 | **Updated:** 2026-09-10

---


## Introduction

Standards documents change quietly. One morning an email titled "For Review" shows up in your inbox, and when you open the link, the document you read last time has a different structure. On September 10, 2026, the W3C Web Accessibility Initiative (WAI) published a new **WCAG 3 (3.0) Working Draft** and sent out a call for review comments.

{{< img src="images/contents/red-pen-open-pages.jpg" alt="A red pen resting beside the fanned-out pages of an open book - standards drafts get revised this quietly, and this often" caption="Photo: <a href='https://unsplash.com/@emmanuelphaeton' target='_blank' title='Opens in new window'>Emmanuel Phaeton</a> / <a href='https://unsplash.com' target='_blank' title='Opens in new window'>Unsplash</a>" >}}

This post is a direct comparison between that September draft and its immediate predecessor, the March 3, 2026 draft. I covered the March draft in [WCAG 3 Status Check: A Complete Rundown of the March 2026 Draft](/en/posts/wcag-3-status-2026/) — and one of that post's key sections just got flipped on its head.

For context, a **Working Draft** is the earliest of several stages a W3C standard passes through on its way to becoming a full Recommendation. The draft's own preamble even says not to cite it for anything beyond ongoing work. Keep that in mind as you read everything below.

## In One Line — Levels Move From Conformance to Reporting

The biggest change in the September draft comes down to a single sentence. Here's the editor's note from section 3.2 of the draft, verbatim:

> This update to WCAG 3 moves the concept of leveling from conformance to reporting. To keep this clear, we refer to "reporting tiers" to distinguish them from previous "conformance levels".

In plain terms, the draft **pulls the concept of leveling out of conformance and moves it into reporting**. In the March draft, Bronze/Silver/Gold were conformance levels — you needed Bronze just to be minimally conformant, with Silver and Gold sitting above it. In the September draft, there's only one conformance state: meet every Core requirement and you conform; miss even one and you don't. Bronze/Silver/Gold have been demoted to tiers that report how much more you did on top of conforming. To avoid confusion with the old term, the draft coins a new one — **reporting tier** — instead of "conformance level."

This is a big enough shift that you should reread the "Bronze/Silver/Gold Are Back" section of [WCAG 3.0 Conformance Model: Moving Beyond A/AA/AAA](/en/posts/wcag-3-scoring-conformance/) and the equivalent section of the March status post with this new context in mind. I've added update notices to both.

## Wait, Three Terms First — What Are Core, Supplemental, and Assertion?

I already used the phrase "Core requirement" above, and if you're new to WCAG 3, that's probably where you stopped short. This whole post rests on three terms. WCAG 3 splits the provisions it defines into three kinds:

- **Core requirements**: What you must meet to conform. Things like "non-decorative images have alternative text that conveys the same meaning" live here. It plays roughly the role WCAG 2.2's A and AA success criteria used to play.
- **Supplemental requirements**: Good to meet, but not required for conformance. Something like "videos over five minutes let you jump to chapters" — one step further than Core. It resembles AAA, though the two aren't identical.
- **Assertions**: Not code, but a documented statement about something an organization did. Things like "we ran a plain-language review on this content," disclosing who did what and when. WCAG 2 had nothing like this.

There's also a fourth category unrelated to conformance, **Recommended practice**, but the current draft has only one item under it, so it's safe to set aside for now.

One more thing: **conformance**, as I use it throughout this post, means "the content meets this standard's requirements" — not "meets a legal obligation" (compliance). The editor's note in the draft's chapter 3 points out that the two get conflated a lot. That's why WCAG 3 defines conformance narrowly and normatively, and plans to push reporting and policy use into a separate guidance document. It's the same distinction as saying "we comply with Korea's Anti-Discrimination Against Persons with Disabilities Act" and "we conform to WCAG 3" — two different claims.

## Six Reporting Tiers — Two Below Conformance, Three Above

The whole new structure lives in a single table in section 4.1.4 of the draft. Each tier is cumulative — every tier above includes everything required by the tiers below it.

| Tier | Name | What It Takes |
|---|---|---|
| 1 | Avoid physical harm | Meet Core requirements tagged Physical harm or Risk |
| 2 | Foundational access | Tier 1 + Core requirements tagged Barrier |
| 3 | **Conformance** | Tier 2 + Core requirements tagged Friction = **all of Core** |
| 4 | Bronze | Tier 3 + Supplemental requirements and content Assertions [count TBD] |
| 5 | Silver | Tier 4 + more Supplemental requirements and content Assertions [count TBD] |
| 6 | Gold | Tier 5 + organization Assertions [count TBD] |

{{< img src="images/contents/wcag3-reporting-tiers-en.png" alt="A ladder diagram of the six reporting tiers in the WCAG 3 September draft - from the bottom: avoid physical harm, foundational access, conformance (all Core met), Bronze, Silver, Gold, with a bold baseline drawn at the conformance tier, labeled 'the path to conformance' below and 'beyond conformance' above" caption="Conformance is a single line. Below it you report progress; above it you report extra achievement." >}}

Notice that tier 1 is literally named "avoid physical harm." The starting line here is not knocking someone out with a flashing screen. That's a pretty serious bar for a starting line.

If you're used to WCAG 2.2, you're probably wondering how A/AA/AAA map onto this table. Get that mental map lined up once and the rest reads easily.

| Aspect | WCAG 2.2 | WCAG 3 September Draft |
|---|---|---|
| What counts as "conformant" | Three states — A, AA, AAA (meeting any one makes you conformant at that level) | **Just one** (all of Core met = tier 3) |
| Falling short of conformance | Simply "non-conformant" | Reported as tier 1 or 2, showing how far you've come |
| Going beyond conformance | AAA on top of AA | Reported as tiers 4-6 (Bronze/Silver/Gold) |
| What determines the level | The A/AA/AAA level attached to each success criterion | The tag attached to each requirement |

Which means we should figure out what "tags" in that last row actually are.

### The Four Tags for Core Requirements — How Bad Is It If You Miss One

The September draft signals that every Core requirement will eventually get tagged based on the worst-case severity of missing it — the draft's own wording is "will be tagged." **The tag categories themselves are set, but which tag attaches to which requirement isn't in this draft's body yet.** Scan all 216 requirements and you won't find a single Barrier or Friction label anywhere.

- **Physical harm**: Missing this can cause immediate physical harm to a person with a disability. Flashing content that triggers photosensitive seizures is the classic example.
- **Risk**: Missing this creates undue financial, medical, legal, privacy, or security risk.
- **Barrier**: Missing this blocks progress outright — a modal you can't escape with a keyboard, for instance.
- **Friction**: Missing this makes progress harder. One alone might not stop you, but enough of them piling up will.

Tags don't affect conformance itself — you still need every Core requirement met, tags or not, to conform. What tags do is let you report how far short of conformance you are, in gradations. The draft acknowledges that the same requirement can vary in severity depending on context: a missing alt text on an image that doubles as a button is far worse than one on a decorative image. So tags are assigned by "maximum potential severity," and the draft notes that adjusting severity at actual reporting time is still being explored separately.

### Two Assertion Tags — Content and Organization

Assertions — an organization's documented statement that it did something for accessibility, covered in [Assertions: A New Unit for Accessibility Evaluation](/en/posts/wcag-3-assertions/) — get tagged too.

- **Content**: Procedures that verify the content itself is accessible: plain-language review, usability testing, assistive-technology testing, style guides, and so on.
- **Organization**: Procedures that help the organization produce accessible content in the first place: staff accessibility training, a public accessibility statement, and so on.

In the tier table above, Bronze and Silver call for content Assertions, and Gold calls for organization Assertions. Gold, in other words, asks not just "how accessible is our site" but "how does our organization actually handle accessibility." That said, an editor's note leaves open whether Assertions will ever become a conformance requirement at all.

### Walking Through It — What Tier Would Your Site Land On? (A Hypothetical)

Let's walk through a made-up example to make the structure concrete. Since tags haven't actually been assigned to requirements yet, everything below is an "if this tag were assigned" hypothetical — don't use it for real judgments.

Say an audit of some team's site turned up this:

1. No flashing banners — the flash-related Core requirement is met.
2. The checkout form's error messages don't reach the screen reader — the error-notification Core requirement isn't met.
3. The thumbnail and title in a search result both link to the same place — the Supplemental requirement isn't met.
4. There's never been a documented plain-language review process — no content Assertion.

Suppose the flashing requirement carries a Physical harm tag, and the error-notification one carries a Barrier tag. Every Physical harm and Risk requirement is met, so tier 1 (avoid physical harm) passes. But that one Barrier-tagged failure keeps the site from tier 2 (foundational access) — and obviously from tier 3 (conformance) too. Items 3 and 4 are about tiers above conformance, so they don't even enter the calculation yet.

Under WCAG 2.2, this site's result would be a single line: "fails AA." Under the September draft's structure, it becomes "passes tier 1; one error-notification fix stands between here and tier 2." The report tells you what's left to fix and how far you have to go. This is exactly why the draft pulled levels out of conformance.

## Why the Change — "Conformance Is a Base, Not a Ceiling"

Section 7 of the Explainer — the companion document that describes WCAG 3's background and structure, also updated in September — lays out two reasons.

First, products that aren't conformant yet now get a ruler to measure progress against. In WCAG 2, missing even one success criterion meant "non-conformant" — full stop. Fix thirty issues and the report still read the same word. Now you can say something like "past avoiding physical harm, working toward foundational access."

Second, borrowing the Explainer's own words, **"conformance is a base, not a ceiling."** The tiers above conformance show how much of the recommended practice an organization has adopted, and how mature its accessibility practice is. The draft also leaves room for a regulator to require a higher tier from a given organization.

In the March status post, I wrote that tiers felt "less like a menu of destinations you pick from, and more like a vocabulary for saying where you currently stand." The September draft restructured things to actually match that read. Now that levels are separated from the conformance verdict, "we're Bronze, so this is as far as we go" doesn't really hold up as logic anymore — conformance is just one thing: all of Core, met.

### A Scoring Alternative, Left Open — In the Explainer Only, Not the Draft

Here's an easy point to get confused on. Section 7.1 of the Explainer includes a section called "Alternative approach - Scoring." It assigns a weight to each tag (3 points for Physical harm and Risk, 2 for Barrier, 1 for Friction and everything else) and turns the fraction met into a percentage. Above conformance, it "awards" Bronze/Silver/Gold based on how many Supplemental requirements and Assertions you've met.

The section explicitly states that it's **not included in the WCAG 3 draft itself**. The working group is soliciting feedback on which approach — tags or scoring — works better, so the two sit side by side for now. If you see a summary claiming "WCAG 3 went back to scoring," that's mistaking this section for the draft's actual body. It's also different from the 2021 draft's 0-4 scoring: that scheme scored each item individually, while this alternative just checks whether each requirement is met or not and multiplies by a weight.

## The Conformance Chapter Moves Up a Maturity Stage — From Exploratory to Developing

Every section of the WCAG 3 draft carries a maturity label. It starts at Placeholder, then climbs through Exploratory, Developing, and Refining, on the way to Mature. In the March draft, the conformance chapter (chapter 3) was Exploratory — meaning the direction itself was still up for debate, and the ask was for feedback on that direction. In the September draft, it's moved up to Developing: the broad direction is roughly settled and the details are being filled in, so now the ask is whether it's workable and sensible.

One step, but it matters. In March, even "how many levels should there be" was still open; by September, the skeleton — one conformance state, with reporting tiers above and below it — has consensus behind it. Meanwhile, the list of functional performance statements (sentences describing different functional limitations, like vision, hearing, or cognition) in section 4.2 is still marked Exploratory. It runs to eighteen statements plus an "other" category — nineteen in all — and the draft notes plainly that "these categories will change."

## Counting Requirements By Hand — 182 to 216

Count the draft text by hand and lay it next to the March draft, and here's what you get:

| Item | March 2026 Draft | September 2026 Draft | Change |
|---|---|---|---|
| Categories | 12 | 12 | No change |
| Guidelines | 44 | 46 | +2 |
| Core requirements | 92 | 106 | +14 |
| Supplemental requirements | 61 | 74 | +13 |
| Assertions | 28 | 35 | +7 |
| Best practice → Recommended practice | 1 | 1 | Renamed only |
| **Total items** | **182** | **216** | **+34** |

The net change looks like +34, but cross-reference the item IDs one by one and you find 49 brand-new items and 15 items that disappeared. Most of that 15 didn't vanish outright — they got split apart or renamed.

### The Media Alternatives Guideline Split Into Three

The single "Media alternatives" guideline from the March draft split into three guidelines in September: Transcripts, Sign language, and Accessible media player. That's why guidelines went from 44 to 46. One guideline in March, three in September — if any part of this document is undergoing rapid cell division, it's this one.

Requirements grew right along with it. An item like "Speakers identified," which was a single medium-agnostic requirement in March, now exists separately for transcripts, captions, and audio description in September. 34 of the 49 new items are packed into this media section alone. If you work with video content, this section is worth reading on its own. There are several items with no WCAG 2.2 counterpart at all, like "Media chapters available" (Supplemental), which requires chapter navigation for audio or video over five minutes.

### Text Contrast and Readability Requirements Enter the Working Draft for the First Time

This might surprise you: the March draft's body had **no text contrast requirement at all**. Not because the concept didn't exist — it was still Exploratory, living only in the Editor's Draft (the public working document) and left out of the Working Draft. In the September draft, eight requirements have graduated to Developing under the text-appearance section of the "Text and wording" category, six of them paired as **(minimum) and (enhanced)**, just like WCAG 2.2's AA/AAA pattern. "Text contrast sufficient (minimum)" is Core; "(enhanced)" is Supplemental. What's still missing is the actual thing being measured — it's marked **"[contrast measure to be determined]."** The editor's note assumes the new algorithm will factor in font size and weight, but adds that a separate requirement might be needed if the algorithm can't handle red-green color blindness. Whether it sticks with WCAG 2's 4.5:1 or moves to a different perception-based algorithm remains unresolved in this draft too.

In the same section, "Blocks of text readable (minimum)" (Core) requires minimum values for spacing, line length, and line height — the values themselves are still undetermined, and the editor's note specifically says it's looking for research on non-Latin scripts. This is exactly the kind of gap practitioners working in non-Latin scripts like Korean can weigh in on.

### Items That Got Renamed or Had Their Criteria Adjusted

A few of the more noticeable ones:

- **No flashing → No flashing over threshold**: The March draft required "no flash in content" (with exceptions only when essential). The September draft changed this to "flashing stays below the general and red flash thresholds" — bringing it back to a structure like WCAG 2.2's 2.3.1 (the three-flashes-per-second threshold). The stricter version was split off as a Supplemental "(no exceptions)" requirement — so what was "no flashing at all" in March became "apply the threshold, with no size exception" in September, loosening things slightly even as it split.
- **No repetitive links → No repetitive adjacent interactive elements**: What used to apply only to links now covers any adjacent interactive elements that produce the same result. A card component where the thumbnail and title link to the same place is still the go-to example.
- **Keyboard navigable if responsive, removed**: The Core item requiring keyboard navigation to work at every breakpoint in a responsive design is gone from the September draft. The word "responsive" doesn't appear anywhere in the body anymore. Keyboard operability itself hasn't disappeared — it reads like the working group decided a separate responsive-specific condition wasn't necessary.
- **Best practice → Recommended practice**: Just a rename. The one item under it is still "Return to start prominent," and its character as a non-conformance recommendation hasn't changed.
- **Summaries available** (Core, new): Requires a summary for long-form text over 300 words — one that's identifiable as a summary both visually and through assistive technology. The draft notes that whether the word-count threshold should vary by language needs research. Whether "300 words" even means anything consistent for Korean is itself an open question.

## What's Still Blank

In the March status post I wrote that there were a lot of blanks. Some have since been filled in; others haven't moved.

{{< img src="images/contents/puzzle-missing-piece.jpg" alt="A blue jigsaw puzzle with one piece missing - tag assignment, tier thresholds, and the contrast algorithm are still blank in the September draft" caption="Photo: <a href='https://unsplash.com/@ttepavac' target='_blank' title='Opens in new window'>Tanja Tepavac</a> / <a href='https://unsplash.com' target='_blank' title='Opens in new window'>Unsplash</a>" >}}

- **Where levels sit (filled in)**: The skeleton — tiers as reporting stages above and below conformance — is now settled.
- **Tag assignment (a new blank)**: The meaning of the four tags is defined, but which of the 216 requirements gets Barrier versus Friction still isn't written down anywhere. Until this is filled in, you can't actually compute "which tier" the way the example above did.
- **Tier thresholds (unchanged)**: The number of Supplemental requirements and Assertions needed for Bronze/Silver/Gold is still marked "[TBD]."
- **Contrast algorithm (unchanged)**: What measures text contrast is still undecided.
- **Default accessibility support set (unchanged)**: The concept covered in [WCAG 3 Accessibility-Support Sets: Korea's Blank](/en/posts/wcag-3-accessibility-support-sets/) got some wording polish in September — the default set moved from being described via "HTML methods" to "web methods" — but the default set itself is still undefined. The schedule says the December draft will update this section.
- **A change log that's stopped moving (unchanged)**: Appendix C's change history still only goes up through September 2025. Neither the March draft nor this September draft is recorded there. The only way to actually track what changed, as I've done here, is to compare the body text by hand.

## Timeline — Next Draft in December, CR Snapshot in Q4 2027

The working group's public schedule — a planning document, not a firm commitment — was updated as of September 10 to read like this:

- The September draft was originally slated for Q2; the schedule notes it slipped to early September because it needed to accommodate the conformance model reaching Developing maturity.
- **December 2026**: A Working Draft updating the requirements and accessibility-support sections.
- **Q2 2027**: One more Working Draft.
- **Q4 2027**: A Candidate Recommendation snapshot. Historically, it's taken about two more years from there to a final Recommendation.

The AG Working Group's charter — the document by which W3C approves a working group's scope and duration — has been extended again, this time through October 28, 2026. It ran through August 28 when I wrote the March status post, so it's been extended once more since then. Keep in mind the timeline could still shift again once re-chartering happens.

## What Practitioners Should Do Right Now — Nothing to Change, Something to Say

The conclusion is the same as in March: you don't need to change anything to align with WCAG 3 right now. Maintaining WCAG 2.2 conformance is still the priority, and the draft will change again in December.

What's different from March is that this draft asks specific questions it wants feedback on. The WCAG 3 introduction page poses three questions about the conformance model:

1. Is a single conformance state plus tag-based reporting tiers an improvement over the previous draft's approach?
2. How does it compare to the Explainer's scoring alternative — what are the trade-offs of each?
3. In your role, how would you actually use the path-to-conformance tiers and the beyond-conformance tiers?

Section 1.1 of the draft's body adds a few more: whether there are user needs it's missing, whether the "applies when / except when" phrasing is easy to follow, whether requirements are better broken down this finely or consolidated instead, and whether the changes to conformance and reporting actually help real-world adoption.

There's also feedback that's easier to offer from a Korean-language perspective: "Blocks of text readable," where the editor's note is openly asking for non-Latin-script research; "Summaries available," which questions whether the 300-word threshold should vary by language; and the fact that the default accessibility support set is built around English content. These are blanks that English-speaking participants aren't well positioned to fill.

You can file feedback as [an issue on the wcag3 GitHub repository](https://github.com/w3c/wcag3/issues) — one issue per topic, and a GitHub account is free. If GitHub isn't your thing, you can email public-agwg-comments@w3.org instead; the guidance asks you to put the content directly in the message body, not an attachment. This announcement doesn't list a hard deadline, but if you want it reflected in the December draft, sooner is better.

## One-Page Summary

- **The core change**: Levels have been separated from conformance. Conformance is now just one thing — all of Core met — and Bronze/Silver/Gold have become **reporting tiers** beyond it.
- **Six reporting tiers**: Avoid physical harm → Foundational access → Conformance → Bronze → Silver → Gold. The bottom two report progress; the top three report extra achievement.
- **Tags**: Four for Core requirements (Physical harm/Risk/Barrier/Friction), two for Assertions (Content/Organization). They don't affect the conformance verdict, and which requirement gets which tag is still unassigned.
- **Scoring**: Exists only as an alternative in the Explainer — not in the draft's body.
- **Maturity**: The conformance chapter moved from Exploratory to Developing.
- **Requirement count**: 182 → 216 (Core 106, Supplemental 74, Assertions 35, Recommended practice 1). Most of the growth comes from the media-alternatives section splitting apart.
- **Blanks**: Tag assignment, tier thresholds, the contrast algorithm, the default accessibility support set, and the change log are all still empty or unchanged.
- **Timeline**: Next draft in December 2026, CR snapshot in Q4 2027, charter running through October 28.
- **What to do**: Nothing to change — keep WCAG 2.2. This is a window for giving feedback instead.

---

{{< faq >}}

---

## Other Posts in This Series

- [WCAG 3 Status Check: A Complete Rundown of the March 2026 Draft]({{< relref "/posts/wcag-3-status-2026" >}})
- [WCAG 3.0 Conformance Model: Moving Beyond A/AA/AAA]({{< relref "/posts/wcag-3-scoring-conformance" >}})
- [Assertions: A New Unit for Accessibility Evaluation]({{< relref "/posts/wcag-3-assertions" >}})
- [WCAG 3 Accessibility-Support Sets: Korea's Blank]({{< relref "/posts/wcag-3-accessibility-support-sets" >}})
- [WCAG 3 Migration: Do You Need It Yet? Moving On from WCAG 2.2]({{< relref "/posts/wcag-3-migration-strategy" >}})
- [KWCAG 2.2 vs. WCAG 3: What's Actually Different]({{< relref "/posts/kwcag-vs-wcag-3" >}})

## References

- [W3C Accessibility Guidelines (WCAG) 3.0 Working Draft (2026-09-10)](https://www.w3.org/TR/2026/WD-wcag-3.0-20260910/)
- [W3C Accessibility Guidelines (WCAG) 3.0 Working Draft (2026-03-03)](https://www.w3.org/TR/2026/WD-wcag-3.0-20260303/)
- [Explainer for W3C Accessibility Guidelines (WCAG) 3.0](https://www.w3.org/TR/wcag-3.0-explainer/)
- [WCAG 3 Introduction — Status: In-progress drafts](https://www.w3.org/WAI/standards-guidelines/wcag/wcag3-intro/#status-in-progress-drafts)
- [WCAG 3 Schedule (AG WG GitHub wiki)](https://github.com/w3c/wcag3/wiki/Schedule)

---

> **Note**: This post is based on the **W3C Working Draft dated September 10, 2026**. WCAG 3 is still under development, and its content may change before the final Recommendation is published. Please refer to the original W3C documents when you need to make an actual decision.