Every accessibility conversation about CAPTCHA runs into the same wall. The challenge exists to be hard for machines, and the ways of being hard for a machine have historically been the ways of being hard for a person who cannot see the image, cannot hear the audio, or cannot complete a drag inside a time limit.
The industry's answer has usually been a parallel path. An audio alternative, or a registration scheme where a disabled user signs up with the CAPTCHA vendor in advance to receive an accommodation cookie. Both work in the narrow sense. Both also mean the disabled user's experience of your website is worse than everybody else's, and that they had to do paperwork with a third party to get there.
The accessibility question is settled before challenge design, by how often a challenge happens at all.
Most legitimate traffic never needs one. Behavioural signals, device characteristics and network reputation resolve it. That describes the invisible CAPTCHA mode, and it is the largest accessibility win available because it applies to everyone without anyone opting in.
When something does need escalating, the first escalation is proof of work. The browser does a small amount of computation and submits the result. The user does nothing. There is no image, no audio, no drag, no timer. It is the one challenge type with no accessibility failure mode, because there is no user task to fail at.
Image challenges come last, reserved for traffic the detectors have already classified as automated, and since August 2026 a site can turn them off completely from the portal. Disabling images routes that traffic to the puzzle instead. If you have an accessibility obligation, that is the setting to change on day one.
A formal WCAG 2.2 AA conformance statement and VPAT are on the roadmap. The product is already built to support them: the widget is keyboard operable and exposes state to assistive technology, and neither the default path nor the first escalation requires a visual or audio task.
If your procurement needs a signed conformance document by a particular date, tell us the date and we will confirm whether we can meet it.
Ticketing and e-commerce, because the European Accessibility Act covers those journeys and because a checkout is exactly where a failed challenge turns into a lost customer who has no way to complain to you.
Public sector and education, where accessibility obligations are usually stricter and older than the commercial ones.
And any site whose support inbox already contains messages from people who could not get past the CAPTCHA. Those messages are the most direct evidence of an accessibility problem available to you.