OpenClearCurrent as of 2026-10-22. Checked against its sources at least once a year (control check regulatory_currency).
OpenClear aims to meet WCAG 2.2 Level AA. This page says what's checked automatically, what isn't yet, and what a VPAT for OpenClear would contain. It isn't legal advice (Compliance).
Who it binds. WCAG is a W3C standard and binds nobody by itself. Section 508 binds federal agencies buying technology, and its standard is WCAG 2.0 AA; a state-chartered bank meets it only as the vocabulary of a VPAT. ADA Title III covers the bank as a public accommodation, but the Department of Justice has no technical web rule for businesses; it and the courts point to WCAG. Its Title II rule (WCAG 2.1 AA) covers state and local governments only, from April 2027. A bank's procurement may ask for a VPAT (CUEC B-SA-4-01).
Checked on every build
- axe-core in Chromium, for WCAG 2.0, 2.1 and 2.2 at levels A and AA, on 22 of the bank's pages (including the in-app guides and the data dictionary) and 9 of a customer's, in light and dark themes, on a desktop and a phone, with three accent colours.
- 73 pages at 360, 768, 1024 and 1280px: axe again, no sideways scroll, touch targets of at least 44px below desktop (and WCAG 2.2's 24px everywhere, through axe), Pay and Return in view on an exception, and a control focused from the keyboard never hidden behind a bar stuck to the bottom of the screen.
- A new problem fails the build. In the markup: a skip link, visible focus, reduced motion
respected, and
autocompleteon the sign-in and password forms.
WCAG 2.2's new criteria
| Criterion | Status |
|---|---|
| 2.4.11 Focus Not Obscured (Minimum), AA | Supports: the page scrolls a focused control clear of the decision bar and the bulk-action bar; the decision bar is checked on every build |
| 2.5.7 Dragging Movements, AA | Supports: the file drop zone is also a file button; nothing else drags |
| 2.5.8 Target Size (Minimum), AA | Supports: 24px at every width (checked by axe), 44px below desktop |
| 3.2.6 Consistent Help, A | Supports: help is in the same place on every page |
| 3.3.7 Redundant Entry, A | Not yet evaluated |
| 3.3.8 Accessible Authentication (Minimum), AA | Supports: password managers and paste work, no puzzle, security keys and passkeys, SSO |
Known gaps
- No manual pass with a screen reader (VoiceOver, NVDA) or the keyboard alone has been done. Automated
checks find about a third of WCAG's problems; the rest (meaningful structure, focus order, error
text, status messages) need a person. It's parked until a tester is available
(
plans/PARKED_PLAN.md). - Some pages have more than one top-level heading (
plans/FULL_REVIEW_PLAN.mdU7).
A VPAT
ITI's VPAT 2.5Rev (April 2025): the WCAG edition (WCAG 2.2 A and AA), or the INT edition for a bank that asks for Section 508 too. It gives the product and version; how it was evaluated (the automated checks above and the manual pass); each criterion as Supports, Partially Supports, Does Not Support or Not Applicable, with remarks; and the software (Chapter 5) and documentation and support (Chapter 6) sections. OpenClear will publish one once the manual pass is done.
Sources
Read 22 October 2026: WCAG 2.2 (W3C Recommendation, 12 December 2024) and Understanding 2.5.8; 36 CFR Part 1194 (US Access Board, amended January 2018); ITI's VPAT 2.5Rev (April 2025); the Department of Justice's Guidance on Web Accessibility and the ADA (March 2022); 28 CFR Part 35 Subpart H and the interim final rule of 20 April 2026 extending its dates.
Built from docs/compliance/accessibility.md in the OpenClear repository. Last changed October 22, 2026.