The European Accessibility Act: What It Means for Mobile Apps
Directive 2019/882 is now enforceable across all 27 EU member states. This page covers what the law requires, who it applies to, and how to make your iOS and Android apps compliant.
Status: Enforcement Active
The Deadline of June 28, 2025, Has Passed.
Directive (EU) 2019/882 is now in its enforcement phase. The transition period has ended. Regulators across all 27 EU member states are now checking digital products and services, including mobile applications, that are available in the European Single Market.
Executive Summary: Directive 2019/882
For the C-Suite (CEO/CTO/GC):
The European Accessibility Act (EAA) is not a set of guidelines. It is a law that requires equal access to products and services for people with disabilities. Unlike the ADA in the US, which is mostly shaped by court decisions, the EAA is written directly into law. It requires that certain products and services meet the EN 301 549 standard (the European version of WCAG 2.1 AA) before they can be legally sold or used in the EU.
The Core Mandate:
Any business selling products or services in the EU must make sure they are perceivable, operable, understandable, and robust. This applies no matter where the company is based. If you sell to Europe, you must comply with European law.
The Mobile App Challenge
Native mobile apps are the most common area where businesses fall short. Many organisations made their websites accessible and assumed that was enough. It is not. The EAA specifically covers mobile services like banking apps, shopping apps, and ticketing apps. These apps have their own separate accessibility requirements.
Why mobile apps need their own attention:
- iOS (VoiceOver) and Android (TalkBack) work very differently from browser-based screen readers. Making a website responsive does not fix accessibility issues in a native app.
- EN 301 549 includes rules that only apply to native mobile software, such as focus order, gesture alternatives, screen orientation, and use of platform accessibility APIs. These have no direct web equivalent.
- Regulators have the power to remove non-compliant apps from app stores and other distribution channels.
Scope & Industries: Who Is Affected?
The EAA covers sectors that are essential to everyday life. If your business operates in any of these areas, your digital products, including mobile apps, are in scope:
E-commerce Services
Online retailers, marketplaces, and booking engines (checkout flow, account management).
Consumer Banking & Finance
Retail banking apps, investment platforms, and mobile wallets (SCA methods, identification).
Transport Services
Air, bus, rail, and waterborne ticketing/check-in services.
Digital Media & E-books
E-readers, software, and DRM accessibility.
Enforcement & Penalties
Enforcement is now active across the EU.
- Each EU country has a Market Surveillance Authority (MSA) responsible for checking products. They carry out spot checks.
- EU consumers now have a stronger legal basis to take action against inaccessible products. Group lawsuits are becoming more common.
- Fines vary by country but are designed to be significant. The most serious penalty is market exclusion, which means a product is removed from the EU market entirely.
Compliance Roadmap
Getting compliant is a step-by-step process. Here is a practical path from assessment to resolution.
Phase 1: Structured Audit (Days 1–5)
Goal: Understand where you stand.
Before making changes, you need a clear picture of how your mobile apps measure up against EN 301 549 and WCAG 2.1 AA.
- Add your iOS and Android apps to AUDITSU and define the key surfaces (screens, flows, and interactions) that need to be checked.
- AUDITSU's Audit Toolkit creates specific test actions for each surface against each requirement, with built-in guidance. Record pass or fail results with notes and evidence. No code access or accessibility expertise needed.
- Test your most important flows with VoiceOver on iOS and TalkBack on Android. Check focus order, gesture alternatives, and screen reader announcements.
Phase 2: Accessibility Statement (Day 6)
Goal: Be transparent about your current status.
The EAA requires you to publish an Accessibility Statement. AUDITSU's Statement Generator uses your audit results to create a statement that is ready to publish and tailored to the right legal requirements.
- Use the data from Phase 1 to clearly list any issues and their impact.
- State which issues you are working on and when you expect to fix them. Being open about this shows good faith to regulators.
Phase 3: Remediation (Weeks 2–12)
Goal: Fix the issues.
AUDITSU's Ticket Manager turns audit failures into tracked tickets. Assign owners, set severity levels and due dates, and track progress through to completion.
- Start with the issues that stop users from completing tasks, such as inaccessible login, broken navigation, or missing screen reader support on key flows.
- iOS and Android often have different accessibility gaps. Track fixes separately for each platform.
FAQ
Q: We are a US-based company. Does this apply to us?
A: Yes. The EAA applies based on where you sell, not where you are based. If you sell to the EU, you must comply.
Q: Can we use an accessibility overlay or widget?
A: No. Overlays do not meet the requirements of EN 301 549 and EU regulators view them with suspicion.
Q: We are B2B only. Are we exempt?
A: Mostly, but check your contracts. Many enterprise buyers now require EAA compliance from their suppliers.
Q: Is PDF accessibility included?
A: Yes. Bank statements, e-tickets, and product manuals all need to be accessible.
Q: Do I need technical expertise?
A: No. AUDITSU's Audit Toolkit is built for compliance officers and product leaders, not developers. The platform gives you structured test actions with built-in guidance. No code access needed.
Start With a Structured Audit
AUDITSU's Audit Toolkit walks you through EN 301 549 compliance for your iOS and Android apps, one surface and one requirement at a time. No expertise needed.