European Accessibility Act for Mobile Apps

In short: since 28 June 2025 the European Accessibility Act (Directive (EU) 2019/882) requires certain consumer services in the EU to be accessible – and it explicitly covers mobile apps used for e-commerce, consumer banking, e-books, electronic communications and the digital parts of passenger transport. The practical benchmark is the harmonised standard EN 301 549, whose web requirements map to WCAG and whose software clause covers native apps. Microenterprises providing services (fewer than 10 people and no more than €2 million turnover or balance sheet) are exempt. If your app sells to EU consumers, build accessibility into design and development now; retrofitting it later costs far more.

This guide explains which apps are affected, what "accessible" means in practice for iOS and Android, the transition rules, and how to make it part of an app project from day one. It is general information, not legal advice.

What the European Accessibility Act is

The European Accessibility Act (EAA) is an EU directive adopted in 2019. Member States had to apply its measures from 28 June 2025. It sets common accessibility requirements for a list of products (such as smartphones, computers, e-readers, ATMs and ticket machines) and services provided to consumers. Each country enforces it through its own authorities and sets its own penalties, so details vary between, for example, Sweden, Denmark and Finland – but the requirements are the same across the EU.

Which apps are covered

Article 2(2) lists the services in scope when provided to consumers after 28 June 2025. For app owners the important ones are:

Apps outside these categories – an internal tool for your staff, a B2B-only portal, a game with no purchase flow – are generally not covered by the EAA itself, though public-sector apps fall under the separate Web Accessibility Directive and accessibility is good practice everywhere.

Who is exempt

The directive defines a microenterprise as an enterprise that employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding €2 million. Microenterprises providing services are exempt from the service accessibility requirements. Two cautions: the exemption is about your company size, not the size of the app; and if you grow beyond the threshold, the obligations apply. Other businesses can rely on the "disproportionate burden" or "fundamental alteration" exceptions only after a documented assessment (Article 14) – it is not a general opt-out.

Transition rules

• Service providers may keep using products they lawfully used before 28 June 2025 to provide similar services during a transitional period ending 28 June 2030.
• Service contracts agreed before 28 June 2025 may continue unchanged until they expire, but no longer than five years from that date.

Neither rule is a reason to launch a new app that is not accessible: a new app is new, and an app that will be live in 2030 needs to meet the requirements anyway.

What "accessible" means: EN 301 549 and WCAG

The EAA describes requirements in functional terms – information must be perceivable, operable, understandable and robust. The detailed, testable benchmark is the European standard EN 301 549 ("Accessibility requirements for ICT products and services"), published by ETSI. Version 3.2.1 (2021) maps web content to WCAG 2.1 Level A and AA and contains a separate software clause that applies to native mobile apps; ETSI published a newer version, 4.1.1, in 2026. When you brief a development team, ask them to state which version they test against.

WCAG was written for the web, but most of its success criteria translate directly to apps. The table shows what that means on a phone.

How to build accessibility into an app project

1. Put it in the brief. State that the app must meet EN 301 549 for the services it provides, and which version.
2. Design for it. Contrast, text scaling, touch targets and labels are design decisions. Fixing them in code after approval costs more.
3. Use native components where possible. Standard platform controls come with most accessibility behaviour built in; heavily custom controls need extra work. This applies to cross-platform frameworks too.
4. Test with real assistive technology during development, not only before launch.
5. Check third-party parts. Payment sheets, identity providers, chat widgets and embedded web views must be accessible as well – ask your providers.
6. Publish accessibility information. Article 13 and Annex V require service providers to explain publicly how the service meets the accessibility requirements, in an accessible format.
7. Keep it up. Every new feature and OS update is a chance to break accessibility. Include checks in regression testing.

Does this matter for US companies?

Yes, if they provide covered services to consumers in the EU. The EAA is about the EU market, not where your company is registered. A US e-commerce or fintech app with EU customers should treat EN 301 549 as part of its requirements. Many of the same practices also help with accessibility expectations in the US, where WCAG is the common reference.

What it means for budget and timeline

Accessibility built in from the start is mostly a matter of discipline in design and testing. Retrofitting an existing app – relabelling hundreds of controls, redesigning low-contrast screens, rebuilding custom gestures – is where the cost appears. When you compare quotes, ask whether accessibility testing is included and how it is done; our checklist for choosing an app development company covers the other questions. For Nordic-specific requirements such as BankID and Vipps MobilePay, see Nordic app development.

Planning an app for EU consumers? Our mobile app development process includes UX/UI design and device testing for Android and iOS – tell us about your project and the requirements it has to meet.

FAQ

Does the European Accessibility Act apply to mobile apps?

Yes, for the services it covers. The directive explicitly includes mobile device-based services in its definition of e-commerce services and names mobile applications for passenger transport services. Consumer banking, e-books, electronic communications and access to audiovisual media are also in scope.

When did the European Accessibility Act take effect?

Member States had to apply its measures from 28 June 2025. A transitional period until 28 June 2030 applies to products that service providers were already lawfully using before that date.

Are small businesses exempt from the EAA?

Microenterprises providing services are exempt: companies with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Companies above that size are covered.

Which standard should an accessible app meet?

EN 301 549, the European standard for accessibility of ICT products and services. Version 3.2.1 maps web content to WCAG 2.1 Level AA and includes a software clause for native apps; ETSI published version 4.1.1 in 2026. Agree with your developer which version you test against.

Does the EAA apply to companies outside the EU?

It applies to covered services provided to consumers in the EU, so a non-EU company serving EU consumers with, for example, an e-commerce or banking app should plan for it. Confirm your specific obligations with a lawyer.

How do I test an app for accessibility?

Use the app with VoiceOver on iOS and TalkBack on Android, set the largest system text size, check colour contrast, complete every task without complex gestures and rotate the device. Combine manual testing with automated checks during development.

Sources (checked 2 November 2026): Directive (EU) 2019/882 (European Accessibility Act) — Article 2 (scope), Article 3 (definitions), Article 4(5), Article 13, Article 14, Article 31, Article 32 (text as adopted, also on EUR-Lex); European Commission — European Accessibility Act; ETSI — EN 301 549 publication archive (V3.2.1 2021, V4.1.1 2026).