WCAG 2.2 & EU 2026: Simple Audio and Video Accessibility Checklist for SMEs

WCAG 2.2 & EU 2026: A Simple Audio/Video Compliance Checklist for SMEs

If you sell products or services in the EU, 2026 is a big year for accessibility. The European Accessibility Act (EAA)and updated EN 301 549 standard mean that many small and medium-sized businesses now have to make their digital content — including audio and video — accessible.

The good news: you don’t need to become a lawyer or accessibility engineer to get started. This article gives you a plain-English checklist based on WCAG 2.2 and EU accessibility rules, focused specifically on audio and video for SMEs.

No legal jargon. Just: Do this → you’re much safer.

TL;DR – 10-Point Audio/Video Compliance Checklist for SMEs

For each audio or video on your site or app, aim for:

1. Captions for all pre-recorded speech (closed captions, not auto-generated only).

2. Transcripts for all audio-only content (podcasts, interviews, voice notes).

3. Audio description or equivalent for key visual information in videos (or descriptive voiceover / detailed text).

4. Accurate timing: captions are synced with speech and important sounds.

5. Accessible player controls: pause, play, volume, captions toggle, full screen — all usable with keyboard and assistive tech.

6. Visible focus on player controls (you can see which button is “active” when tabbing).

7. Tap-friendly buttons: main controls meet WCAG 2.2 minimum size/spacing (around 24×24 CSS pixels or enough spacing).

8. No blocking auto-play: if media auto-plays, users can easily pause/stop it and it doesn’t trap keyboard focus.

9. Consistent help: if you provide a help option around your media (chat, support link), it appears consistently across pages.

10. Documented process: you have a simple internal process to check new audio/video before publishing.

If you follow this list, you’re aligning with WCAG 2.2 AA principles and the EU’s EN 301 549 / EAA expectations for audio and video. 

1. Why SMEs must care about 2026

European Accessibility Act (EAA) and who it hits

The EAA sets EU-wide minimum accessibility requirements for a wide range of products and services, including many digital ones. It becomes enforceable in June 2025, with specific deadlines for compliance.

In many member states:

• Micro-businesses (under 10 employees or under about €2M turnover) may be exempt.

• SMEs above that threshold are expected to comply when providing digital services (e-commerce, media, banking, online platforms, etc.). 

Even if you’re exactly on the edge of exemption, there are good reasons to act:

• Avoid complaints and reputational damage

• Make content usable for customers with disabilities

• Be ready as regulations tighten

How WCAG 2.2 fits in

WCAG 2.2 is the latest version of the global web accessibility guidelines, focused on making content more usable for people with cognitive, mobility and low-vision disabilities. It adds several new success criteria and updates others, especially around focus visibility, target size, and help consistency.

EU standards like EN 301 549 incorporate WCAG criteria for web and software accessibility. So working towards WCAG 2.2 AA for your audio/video experience is a very strong move toward EU compliance.

2. Captions for video: what “compliant” really means

For pre-recorded video with speech, you should provide captions (closed captions / subtitles for the deaf and hard-of-hearing) that:

• Include all spoken dialogue

• Capture essential non-speech sounds (e.g. [laughter], [music], [door slams])

• Are synchronised with audio

• Are accurate enough that users can follow the content without guessing

Under the EAA and related guidance, captions are expected for a wide range of broadcast, streaming, and online videoto make content accessible to people with hearing loss. Some guidance for live content is already pointing to accuracy targets near 98–99% for captions used by broadcasters and public entities. 

Minimum SME action:
For any video that markets, explains, or trains around your products/services, treat captions as mandatory, not optional.

3. Transcripts for audio-only content

For audio-only material (podcasts, interviews, customer stories, internal recordings you share), provide a full text transcript that:

• Includes all spoken words, with speaker labels where needed

• Notes essential sounds that affect meaning (e.g. “[phone rings]”)

• Lives on the same page or clearly linked from the audio player

Transcripts are not only better for accessibility; they also help with search, SEO and quick skimming for busy users.

Minimum SME action:
If someone can click “play” on a speak-only file, they should also be able to read that content.

4. Audio description and visual information

Some users can hear the audio but cannot see what is happening on screen. For them, key visual details must be:

• Narrated in the audio track (“The presenter points to a highlighted red section of the chart labelled ‘Risk’”), or

• Provided via a separate audio description track, or

• Clearly described in visible text near the video (e.g. a detailed summary)

The European Accessibility Act and EN 301 549 both treat audio description and equivalent alternatives as important for audiovisual accessibility, especially in broadcasting, streaming and public information content.

Minimum SME action:
If your video relies on visuals to explain something important (diagram, product UI, chart), make sure that information is also available as speech or text.

5. Making the media player itself WCAG 2.2-friendly

Even perfect captions won’t help if people can’t operate the video/audio player.

Keyboard accessibility

Your player controls (play, pause, volume, full screen, captions toggle) should:

• Be reachable via keyboard only (Tab, Enter, Space, Arrow keys)

• Have a clear focus indicator showing which control is active

• Not be hidden behind sticky headers or footers when focused

WCAG 2.2 adds more emphasis on focus visibility and focus not being obscured, so this is now even more important.

Target size & spacing

Small, tightly packed buttons are hard for people with tremors, limited dexterity, or those using touch screens.

WCAG 2.2’s Target Size (Minimum) criterion expects interactive elements to be at least around 24×24 CSS pixels, or to have enough spacing that a 24×24 area around each doesn’t overlap.

Minimum SME action:

• Use a reputable, accessibility-aware media player.

• Check that you can fully operate it by keyboard and that you can clearly see where the focus is.

• Make sure play/pause and captions buttons are big enough and not crammed together.

6. Auto-play, motion, and user control

Accessibility standards require that users stay in control of moving, blinking, or auto-playing content.

For audio and video, that means:

• If media auto-plays, users must be able to pause or stop it quickly.

• Auto-play should not trap focus or make it hard to navigate elsewhere.

• Long-running audio/video shouldn’t be impossible to pause using keyboard or assistive tech.

EN 301 549 and EU guidance emphasise user control over media as part of accessible service design.

Minimum SME action:

• Avoid auto-play where you can.

• If you use it (e.g. hero background video), make sure there is an obvious, accessible way to stop or mute it.

7. A practical 5-step plan for SMEs

You don’t have to fix everything overnight, but you do need a plan.

Step 1 – Inventory your audio and video

List:

• All videos on your website

• Webinars and recordings

• Podcasts and audio files

• Embedded media from platforms you don’t fully control

Mark what already has captions/transcripts and what doesn’t.

Step 2 – Prioritise high-risk content

Start with:

• Public-facing product or service videos

• Training and onboarding content

• Videos used in sales, support, banking, government or health contexts

• Content going to EU markets where EAA applies

Step 3 – Choose your caption/transcript approach

Options:

• Human-created captions/transcripts (highest accuracy)

• Hybrid (AI draft + human editing)

• AI-only for low-risk internal content

For anything tied to compliance or public information, avoid relying on AI-only captions.

Step 4 – Fix the player experience

• Use a player known to support accessibility standards.

• Test with keyboard, screen reader where possible, and small touch devices.

• Ensure buttons meet minimum size and focus visibility expectations.

Step 5 – Build a simple “accessibility check” into your publishing flow

For every new audio/video, ensure that:

• Captions/transcripts are either attached or ordered

• Visual-only information is also described

• Player controls work accessibly

Write this into a short checklist for your marketing / content / product team.

8. FAQ for SMEs

Do I really need captions for every single video?

For any video your customers rely on to understand your product or service, yes, you should treat captions as standard. For purely decorative or internal one-off clips, you may accept more risk, but the direction of EU law is more captioning, not less.

What about live events and webinars?

Live captioning is increasingly expected, especially for public events and larger organisations. At minimum:

• Provide live captions if the event is significant.

• Always provide recordings with full captions and transcripts afterward.

Are micro-businesses really exempt?

The EAA allows exemptions for very small businesses, but details vary by country and there are concepts like “disproportionate burden” that can be complex. Even if you are technically exempt, making your content accessible is still best practice and can prevent complaints.

Is “auto-captions” from platforms enough?

For high-stakes or public-facing content, no. Auto-captions often fall short of the accuracy and reliability expected under accessibility law and guidance, especially for names, numbers, and technical terms. Human review or human-created captions are strongly recommended.