1. Overview
Principle 3 of WCAG 2.2 says that "information and the operation of the user interface must be understandable". This principle serves people with cognitive and learning disabilities most directly. But every criterion in it helps everyone. A screen reader reads a page in a declared language in the right voice. A browser translates that page correctly. Anyone finishes a form faster when it says what went wrong, and where. Fewer customers abandon a login that does not demand a memorised password and a solved puzzle.
At Levels A and AA, Principle 3 has three guidelines and thirteen success criteria. Seven are at Level A and six at Level AA. Guideline 3.1 Readable has two criteria. Guideline 3.2 Predictable has five. Guideline 3.3 Input Assistance has six.
Three criteria are new in WCAG 2.2. All three came out of the W3C's work on cognitive and learning disabilities. They are:
- 3.2.6 Consistent Help
- 3.3.7 Redundant Entry
- 3.3.8 Accessible Authentication (Minimum).
A machine cannot test most of this principle. An automated audit can tell you whether a page declares a language. It can tell you whether the fields have labels. Only a person can judge whether a label makes sense. Only a person can judge whether an error message helps. Only a person can judge whether the login is possible without a cognitive test.
For web pages, EN 301 549 clause 9.3 simply requires each WCAG criterion by number. For example, 9.3.1.1 is Language of Page and 9.3.3.8 is Accessible Authentication (Minimum). Clause 11.3 for software is more selective. Three criteria are Void for apps.
Two of the Void criteria are 11.3.2.3 Consistent Navigation and 11.3.2.6 Consistent Help. Both apply to "sets" of web pages. In the standard's words, sets of software programs are extremely rare. The third Void criterion is 11.3.1.2 Language of Parts. It would require the app to mark up every phrase. That is not feasible.
Consistent Identification survives at 11.3.2.4, rescoped to a single program. Clause 11.3.3.8 restates Accessible Authentication in full, with two useful notes. First, the password that unlocks the device itself is out of scope for the app. Second, as the user types a password, what the screen reader says should match what the screen shows, dots for dots.
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Sources
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2, Principle 3, and the Understanding WCAG 2.2 documents, in particular 3.2.6, 3.3.7 and 3.3.8.
- ETSI, CEN and CENELEC, EN 301 549 V4.1.1 (2026-09), clauses 9.3, 10.3 and 11.3 (including Table 11.16) and Annex ZB, available from the ETSI standards server.
- Directive (EU) 2019/882 (the European Accessibility Act), Article 2(2) and Annex I, Sections III and IV.
- Council of Europe, Common European Framework of Reference for Languages: level descriptions, for what level B2 means.