EAA & ADA Hub
EAA for mobile apps
What the European Accessibility Act requires of a mobile app, how it maps to WCAG 2.2 and EN 301 549, and who is exempt.
Updated 20 July 2026 · Technical readiness assessment — not legal advice.
The European Accessibility Act does not talk about SwiftUI or Jetpack Compose. It talks about services being accessible to people with disabilities. For a mobile app, that abstract requirement resolves, in practice, to the technical standard EN 301 549, which in turn leans on WCAG 2.2. This is the chain an audit has to make concrete.
What "accessible" means for an app
In day-to-day terms: every interactive control has a name a screen reader can announce; text survives the largest Dynamic Type setting without clipping; contrast meets the AA minimum; the reading and focus order follow the visual order; and no core task — signing in, buying, deleting — traps or excludes someone using assistive technology.
The mapping that matters
Each finding worth reporting can be tied to a specific success criterion. A missing label is WCAG 4.1.2 / EN 301 549 clause 11.4.1.2. A contrast failure is WCAG 1.4.3. A touch target below 44pt is WCAG 2.5.8 plus Apple's Human Interface Guidelines. If a tool cannot name the criterion, it is giving you an opinion, not an assessment.
Why static scanners fall short here
A static scan can read a binary and flag some issues, and it should. But the failures that actually lock people out — a checkout that cannot be completed with VoiceOver, a modal with no reachable exit — only appear when something uses the app. That requires driving the app in a real environment and recording what happens. That recording is the difference between "we think" and "here it is".
Which apps the Act actually covers
Not all of them, and the difference matters more than the requirements do — a requirement you are not subject to is not a requirement. Article 2(2) names the services: electronic communications, access to audiovisual media, passenger transport, consumer banking, e-books and dedicated software, and e-commerce. Article 2(3) adds answering emergency communications to 112. A fitness tracker, a note-taking app or an internal tool sits outside that list; a fitness tracker with a subscription checkout inside it does not, because selling to a consumer makes it an e-commerce service.
Where you are established is not part of the test. The Act follows the service to the consumer, so a company outside the EU serving EU consumers in a listed sector is in scope.
Who is exempt
A micro-enterprise providing a service is exempt under Article 4(5). The threshold is fewer than 10 people and either annual turnover or annual balance sheet total at or under €2M — both halves, so ten people is enough to fall outside the exemption on headcount alone. The exemption is for services: a micro-enterprise that places a physical product on the market still applies the accessibility requirements and is only relieved of part of the documentation. A mobile app on its own is a service.
There is also a disproportionate-burden exception in Article 14, but it is not a size test and it is not self-declaring — it requires a documented assessment you have to be able to produce. Treat it as a thing you argue, not a thing you are.
Four questions that tell you which of these you are →
What an audit gives you
A readiness score, a severity breakdown, and — for each finding — a recording or a measurement, the mapped criterion, and a concrete fix. Not a certificate, and not legal advice: a technical readiness assessment you can hand to your engineers and, if needed, to your counsel.
If your exposure is American instead
None of the chain above exists in the United States. There is no technical standard a private app is required to meet, the circuits disagree about whether a purely digital service is reachable under Title III at all, and the one federal rule that names mobile apps applies to state and local government. What the US filings actually claim →
This is not legal advice. Requirements and exemptions depend on your specific circumstances; confirm them with a qualified lawyer.