What is Mobile Application Accessibility?
Mobile application accessibility isn’t that unlike web accessibility. It extends the boundaries of the term ‘digital accessibility.’ Ultimately, mobile application accessibility ensures that individuals with disabilities can fully access and interact with mobile applications they would install natively on their devices.
To garner context, we can all assess our own mobile device usage—you might even be reading this blog through a mobile browser!
Now, think about the mobile applications you use daily rather than going to your browser like you would on a laptop or desktop computer. Perhaps you regularly use a banking application to pay your bills, a weather app to make your plans for a weekend adventure or a music app to turn on your favorite songs while you relax.
Most of us use an endless number of mobile applications via our personal devices daily rather than relying on opening up our laptops to perform routine tasks.
But what if these applications are not accessible for people with disabilities who might need them as much as anyone to efficiently and effectively engage with vendors, travel, or order food?
Like website accessibility, mobile application accessibility refers to making native applications compatible with assistive technologies like screen readers (e.g., VoiceOver for iOS and TalkBack for Android in this context) and ensuring the app’s design, navigation, and functionality are user-friendly for all.
Accessibility in this context goes beyond compliance with guidelines like WCAG; it includes a focus on usability, ensuring that everyone can effectively perform critical tasks within the app, regardless of ability.
WCAG and Mobile Application Accessibility: Understanding WCAG in the Mobile Context
The Web Content Accessibility Guidelines (WCAG) are the globally recognized standard for web accessibility, and they have extended relevance to mobile applications.
Even though WCAG was originally intended for web content, its principles also apply to the mobile app environment. WCAG 2.1 (released in 2018) and 2.2 (released in 2023) build upon WCAG 2.0, and one of their main goals was to introduce success criteria that are particularly pertinent to mobile devices that were far less heavily used when WCAG 2.0 was released in 2008.
This naturally makes them the go-to frameworks for assessing mobile app accessibility in the current state of regulations, which we will outline further below.
WCAG 2.1 and 2.2: Key Success Criteria for Mobile Applications
WCAG 2.1 brought forward mobile-specific success criteria, recognizing the unique aspects of mobile devices. Here are a few specific examples:
- 1.3.4 Orientation (AA): This criterion requires that apps not restrict their functionality to a single-screen orientation. A map application, for instance, must work equally well whether a user holds their device in landscape or portrait mode, which is especially important for users who mount their device in fixed positions (such as in a wheelchair).
- 2.5.1 Pointer Gestures (A): Mobile apps often rely on complex gestures, such as swiping or pinching. However, this success criterion mandates that all functionality, such as zooming into a product catalog or adjusting a timeline in a media app, be operable with a single pointer. This ensures that users with limited motor skills can still navigate and operate the app without requiring complex multi-touch gestures that may not be possible.
WCAG 2.2 builds on WCAG 2.0 and 2.1 requirements by adding more precise criteria, further enhancing mobile accessibility. There is one specific success criterion that pertains heavily to mobile devices and applications:
- 2.5.7 Dragging Movements (AA): Dragging elements (e.g., dragging files between folders in a mobile file manager) must be operable without requiring the drag-and-drop motion, making these functions usable by individuals who may have difficulty with fine motor skills.
Why WCAG Alone Isn’t Enough for Mobile Applications
While WCAG lays a solid foundation, mobile applications require additional expertise to ensure they are not only legally conformant with accessibility standards globally but also usable for people with disabilities.
For example, mobile devices rely on gestures (pinch, swipe, tap, drag), custom controls, and unique navigation paradigms that WCAG does not fully address.
Of course, the “W” in WCAG refers to “Web,” there are currently no mobile-specific accessibility guidelines that are leveraged at scale or referenced in global regulations. However, the W3C has engaged a Mobile Accessibility Task Force to articulate how WCAG can be applied to mobile applications more effectively.
In the broader context of WCAG, building accessibility into a mobile app that is both compliant and usable requires more than just ticking boxes on a checklist such as WCAG 2.2; it requires careful testing and evaluation by experts who understand how people with different disabilities use mobile technology in the real world.
This is why Allyant maintains a specialized mobile application auditing team. Our experts go beyond mere compliance, conducting thorough evaluations that consider real-world usage scenarios and leveraging their extensive knowledge to identify and mitigate accessibility barriers.
This includes applying the WCAG success criteria by considering how a user with a disability uses a mobile application in a real-world environment and meaningfully applying these success criteria to ensure mobile developers and designers can effectively remediate issues within their applications.
Partnering for Success
Another thing I always stress to clients is ensuring your team is working with third-party mobile development firms that prioritize accessibility through your application build and ongoing lifecycle.
One of the highest accessibility expenses an organization can incur is when they build websites or applications without any consideration for accessibility.
Therefore, when accessibility testing is eventually done, the organization assumes the expense of retrofitting accessibility fixes into an already built application, which in some cases can be difficult, if not impossible, without full feature rewrites—snowballing the cost of accessibility very quickly.
Collaborating with a mobile app development company that prioritizes accessibility through the entire product lifecycles, such as our partner agency ArcTouch, is essential. ArcTouch, for example, prioritizes accessibility in every development phase, from initial design to ongoing updates.
They integrate accessibility considerations into their workflows, ensuring that features are tested with live users from our team and that accessibility is maintained throughout the app’s lifecycle.
This partnership ensures that your mobile application meets WCAG standards and delivers an exceptional user experience for all.
It also saves your organization significant time and resources in building accessibility requirements into your native applications!
Legal Requirements: Does Your Mobile Application Need to Be Accessible?
The legal requirements for mobile accessibility vary across industries and geographical regions. Here’s a deeper dive into the different scenarios where mobile application accessibility is legally required so your organization can.
1. Public Entities and Government Agencies (Title II of the ADA)
If you are a public entity or government agency—yes—your mobile applications need to be accessible with WCAG 2.1 AA.
Public entities, such as state and local governments, are required to make their mobile applications accessible under Title II of the ADA following updated regulations released by the DOJ in April 2024. This includes apps that provide essential public services or communication platforms.
Specific Examples:
- City and Municipal Services: City or County government apps that allow residents to report issues like potholes in roads or pay utility bills must be accessible. For instance, an app used by residents to pay parking tickets or apply for city permits should allow users to navigate via screen readers or other assistive technology.
- Public Transportation: Apps used to book paratransit services or provide real-time schedules for city buses and trains need to be accessible to individuals who are blind, deaf, or have limited mobility. For example, the NYC MTA app, which allows real-time tracking of buses and subways, must ensure that users with disabilities can fully access schedule information and map features.
The Department of Justice (DOJ) has made it clear that any digital content provided by public entities—including mobile apps—must be accessible to WCAG 2.1 AA.
2. Healthcare Organizations (HHS Accessibility Regulations)
If you are a healthcare organization that accepts Medicare or Medicaid—yes—your mobile applications need to be accessible with WCAG 2.1 AA.
Healthcare providers and insurers that use mobile applications for patient interactions are also required to comply with accessibility laws under the Department of Health and Human Services (HHS) that were released in May 2024. These regulations ensure that patients with disabilities can access healthcare services and information via mobile apps.
Specific Examples:
- Patient Portals: A healthcare provider’s mobile app that allows patients to view their medical history, access lab results, or schedule appointments must be fully accessible. Apps like MyChart, which are used widely in healthcare systems, must ensure that all users can easily navigate their medical data using screen readers or other assistive technologies.
- Telehealth Services: With the rise of telemedicine, mobile apps used for virtual doctor appointments must be accessible. This includes ensuring that users can navigate menus, complete registration, and communicate with providers using both voice and visual cues.
The HHS enforces strict regulations, ensuring healthcare-related apps are accessible according to WCAG 2.1 AA by May 11. 2026. A hospital or other healthcare provider’s failure to make their patient communication or services apps accessible could result in a federal complaint or legal action under Section 504 of the Rehabilitation Act.
3. European Union and the European Accessibility Act (EAA)
If your organization is based in the EU or offers mobile applications to consumers in Europe—yes—your mobile application is required to conform to the WCAG Success Criteria.
If your organization is based in the EU or offers mobile applications to EU consumers, you must comply with the European Accessibility Act (EAA). The EAA requires that mobile apps, websites, and other digital services be accessible to all users, including those with disabilities, by late June 2025.
Specific Examples:
- E-Commerce Platforms: A European e-commerce company offering a mobile app for online shopping must ensure that individuals with disabilities can navigate the app, browse products, and complete purchases. For instance, a Clothing Retailer with a mobile app allowing consumers in Europe to shop the brand’s products is required to ensure that all shopping and checkout features are accessible via screen readers and offer alternatives for touch-based gestures.
- Banking and Financial Services: Mobile banking apps used by EU customers must comply with the EAA. Users should be able to transfer money, view statements, and access financial tools regardless of disability. This includes making features such as biometric logins (fingerprint or facial recognition) accessible.
Failure to comply with the EAA could result in legal penalties for companies operating within the EU.
4. Private Entities and B2C Applications
If you are a non-healthcare-based private entity in the U.S. that does not sell or ship to Europe, maybe your mobile applications need to be accessible with WCAG 2.1 or 2.2 AA.
Private companies offering consumer-facing mobile applications (B2C) may find themselves in a legal gray area, but staying proactive is important.
Although lawsuits specifically targeting mobile apps are still relatively uncommon, several have emerged throughout 2024. At least one high-volume plaintiff specifically targeted mobile applications that do not provide equitable access under the ADA (see Jahoda vs. Ralph Lauren Corporation—Case Number: 2:24cv1195).
These lawsuits and demand letters replicate the high-volume activity from several known plaintiffs targeting websites for lack of WCAG conformance. This trend may increase as mobile application requirements brought forth by the Title II and HHS regulations see their compliance timelines arrive in 2026.
Specific Examples:
- Retail & E-Commerce Apps: While not explicitly mandated, e-commerce apps are increasingly becoming the target of litigation as consumers with disabilities demand greater accessibility, like B2C websites. If your app serves a large audience, especially with complex functionalities like in-app purchases or dynamic product displays, it’s critical to ensure it is accessible to avoid future legal issues while expanding your consumer audience.
- Entertainment and Media Streaming: Mobile apps used for streaming media could also be at risk due to high volumes of users. While these apps are entertainment-focused, they often offer essential services to individuals with disabilities, such as closed captions or descriptive audio. They must ensure that all interfaces are navigable by screen readers.
Potential Legal Trends for 2025 and Beyond
While lawsuits targeting mobile applications are still rare compared to those filed against websites, there is growing scrutiny. As referenced, cases have emerged in which plaintiffs filed claims specifically related to inaccessible native mobile apps.
With Title II and HHS regulations explicitly requiring mobile app compliance, I anticipate a growing trend of litigation targeting inaccessible mobile applications over the next two years and beyond.
Furthermore, as more regulatory bodies explicitly mention mobile applications in their rules AND the use of mobile applications becomes more frequent by people living with disabilities, the legal landscape for mobile apps will almost certainly evolve. This will likely lead to more frequent litigation and more regulatory bodies requiring mobile application compliance by as early as 2025.
Like our recommendation for website accessibility, proactive measures in ensuring accessibility can help private entities avoid potential legal challenges and foster a more inclusive user base. Simply put, it is also the right thing to do and will open up your mobile application to a broader audience!
How Allyant Can Help: Bridging the Gap with Live-User Testing
At Allyant, we offer paired live-user testing. In this method, both blind and sighted mobile accessibility engineers collaborate to identify accessibility barriers and map out a clear path to remediate those issues for your team or development agency. This approach ensures that your app is tested in real-world conditions using native technologies like VoiceOver on iOS and TalkBack on Android.
Our Comprehensive Testing Approach Includes:
- Native Technology Utilization: We leverage built-in accessibility features such as VoiceOver for iOS and TalkBack for Android to simulate real user experiences. We identify not only WCAG violations within your application but also potential usability barriers for users with varying disabilities to ensure you are creating highly usable apps for all.
- VoiceOver is the built-in Screen Reader installed on all iOS devices to provide spoken descriptions of on-screen elements, allowing users with visual impairments to navigate and interact with your native application app efficiently. Our testing ensures that all UI elements are properly labeled, and that navigation flows logically.
- TalkBack offers similar functionality for Android devices, enabling users to receive auditory feedback and navigate the app using gestures. We ensure that all interactive elements are accessible and that the app responds appropriately to various user inputs.
- Paired Accessibility Testing: Our team includes both blind and sighted engineers who work in a “paired” audit process to uncover and address accessibility challenges from multiple perspectives. This paired process is the only real path to creating an equal user experience. For example, if a blind engineer worked solo, there could be various features or content hidden from a screen reader that they could not properly identify – leaving out a subset of your consumers altogether.
- Real-World Scenario Testing: We conduct testing based on common user tasks and scenarios that users would engage within your specific mobile application to ensure that your app performs reliably and intuitively for all users.
- Agile Feedback Integration: Insights from live-user testing are seamlessly integrated into your development cycle (and JIRA instance if needed), ensuring continuous improvement and adherence to accessibility standards both post-assessment and ongoing as you add or change features downstream
Strategically Deploying Your Accessibility Budget with Allyant:
The recent WebAIM Million Survey highlighted that over 90% of users with disabilities use mobile devices, emphasizing the critical need for mobile application accessibility beyond just the legal and regulatory requirements outlined in this article. At Allyant, we help clients strategically allocate their accessibility budget by focusing on efficiency in the scoping process:
- Critical Use Cases: Based on user needs and usage patterns, identify and prioritize the most impactful areas of your app that require accessibility enhancements.
- Framework Compatibility: Working with shared frameworks such as React Native ensures that accessibility features are consistently implemented across multiple platforms, optimizing resource allocation compared to “requiring” you to audit shared frameworks across both iOS and Android devices wherever possible.
- User-Centric Testing: Incorporating live-user testing ensures that your accessibility efforts are aligned with real-world user experiences, maximizing the effectiveness of your budget to solve the most critical access barriers preventing users from engaging with your brand and mobile applications.
Conclusion & Next Steps for Your Organization
In conclusion, ensuring that your mobile application is accessible and WCAG conformant is not just about compliance—it’s about creating an inclusive experience for all users regardless of their preferred digital path for engaging with your organization.
Whether you are bound by legal requirements or simply striving to provide the best possible user experience, Allyant is here to help you navigate the complexities of mobile app accessibility. Our expertise is focused on ensuring that your mobile application meets the highest standards of accessibility and usability.
For more information on how Allyant can assist you in making your mobile applications accessible, contact us today.
