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Why WCAG isn't enough for neurodivergent users

Launch piece, by the Neurodiversity Design Council

WCAG 2.2 is the global standard for digital accessibility. It's thorough, well established and referenced in accessibility law across the UK, the EU and beyond, so a product that meets WCAG 2.2 AA has done something worthwhile, removing barriers for people with visual impairments, hearing loss, motor difficulties and some cognitive needs.

WCAG wasn't designed with neurodivergent people in mind, and the gap between what it covers and what they need is wider than most organisations realise.

What WCAG covers well

WCAG rests on four principles, that content should be perceivable, operable, understandable and robust in the W3C's own terms. It covers colour contrast, keyboard navigation, text alternatives for images, captions for video and dozens of other specific technical criteria. These are real requirements, and meeting them takes work.

For visual, auditory and motor disabilities WCAG is comprehensive. It tells you what to build, how to test it and where the pass mark sits, and that clarity is its greatest strength.

Where the gap starts

Around one in five people in the UK is neurodivergent, including people with ADHD, autism, dyslexia and dyspraxia and a range of co-existing conditions that affect how people process information, manage attention, handle sensory input and regulate emotion.

The W3C publishes supplementary guidance on cognitive accessibility, known as COGA. It's useful, but it's guidance rather than a testable standard, with no pass or fail criteria, no scoring and no certification, so it tells you what to think about without telling you what to measure.

That means a product can meet every WCAG 2.2 AA criterion and still be unusable for a neurodivergent person, because the barriers it puts up are cognitive rather than technical.

What a cognitively hostile product looks like

Picture a dashboard with fourteen notification badges competing for attention, a form with twenty-three fields and no save button, a timed assessment where you know the answer but can't reach it fast enough, or an error message that says 'invalid input' without saying what was wrong or how to fix it.

Every one of those can pass WCAG. The colour contrast is fine, the keyboard navigation works and the headings are properly structured, yet the product still fails the people using it.

WCAG doesn't test for:

• cognitive load, meaning how much mental effort the interface demands
• executive function support, meaning whether the product helps you plan, sequence and finish tasks
• sensory overload, going past colour contrast into notifications, motion and visual density
• emotional safety, meaning whether error handling, feedback and design patterns cause needless distress
• dark patterns, meaning whether the product manipulates people through urgency, shame or deception
• personalisation, meaning whether people can adapt the product to their own needs in any meaningful way

Why this matters commercially

The European Accessibility Act has applied since 28 June 2025, with each EU member state setting its own penalties. In the UK, employment tribunals heard 517 cases linked to neurodivergent conditions in 2025, the largest award reached £850,000 and compensation for disability discrimination has no upper limit.

Organisations that can show they went past WCAG, assessing their product for neurodivergent usability and acting on what they found, are in a far stronger position than those that stopped at the technical minimum.

What the NDC standard adds

The NDC standard, NDC-2026-001, was built to fill this gap. It has seven domains, thirty-five criteria and a maximum of 140 points, covering cognitive load, reading and language, sensory design, predictability, executive function support, emotional safety and personalisation. Each criterion has a defined scoring method, and each assessment produces a structured report with evidence and practical guidance on fixing what it finds.

It sits alongside WCAG, and a product should meet both WCAG 2.2 AA and the NDC standard. WCAG tells you whether a product is technically accessible, and the NDC standard tells you whether it works for the neurodivergent people using it.