EAA 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".

Who is exempt

Micro-enterprises (fewer than 10 staff and under €2M turnover) that provide services are generally exempt. Most funded or revenue-generating app companies are above that line, and companies outside the EU that serve EU users are in scope too.

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.

This is not legal advice. Requirements and exemptions depend on your specific circumstances; confirm them with a qualified lawyer.