The European Accessibility Act (EAA) has been enforced across all EU member states since 28 June 2025. If your company delivers a consumer-facing service through a mobile app in the EU, the law almost certainly applies to you. The enforcement is not theoretical. Disability organisations have filed injunctions in France. Regulators in the Netherlands and Germany have begun audits and warning letters. This is what you need to know.
Does the European Accessibility Act apply to mobile apps?
Yes, when the app is part of an in-scope service. The EAA does not regulate apps as standalone products. It regulates services delivered to consumers. If a mobile app is the interface through which one of those services is delivered, it is in scope.
The distinction matters. The law targets the service, not the technology. A banking app, a retail checkout, a train ticketing flow: these are all services delivered through mobile software. The app is the delivery mechanism, and the EAA requires that mechanism to be accessible.
This means compliance is not limited to your website. If your mobile app delivers the same service, it must meet the same accessibility requirements. Many organisations that addressed web accessibility under WCAG have not yet extended that work to their native iOS and Android apps. Under the EAA, that gap is a compliance risk.
Which mobile apps are in scope?
The EAA covers specific service categories defined in Directive 2019/882(opens in new tab), Articles 2 and 3. If your mobile app delivers any of the following services to consumers in the EU, it is in scope:
- E-commerce. Online shops, marketplaces, and any app that allows consumers to browse, select, and purchase products or services.
- Banking and payment services. Consumer banking apps, payment platforms, digital wallets, and financial service apps.
- Passenger transport. Air, bus, rail, and waterborne transport services, including ticketing, check-in, and real-time travel information.
- Electronic communications. Telecoms services, messaging platforms, and VoIP apps that serve consumers.
- Audiovisual media. Streaming services, video-on-demand platforms, and any app delivering audiovisual content.
- E-books. E-book readers, digital publishing platforms, and apps that distribute e-books.
B2B-only apps are generally out of scope unless they deliver a consumer-facing service. A retail banking app used by consumers in Germany is in scope. An internal HR tool used only by employees is not.
What about apps from companies outside the EU?
The EAA applies to any company providing in-scope services to EU consumers, regardless of where that company is incorporated. The test is whether the service reaches EU consumers, not where the company is headquartered.
A US fintech with a payments app available in the German App Store is in scope. A UK transport company selling tickets to passengers travelling within the EU is in scope. A Japanese e-commerce platform that ships to EU addresses and accepts orders from EU consumers is in scope.
This is consistent with how the EU applies other consumer protection regulations, including the GDPR. If you serve EU consumers, EU rules apply.
What standard does my app need to meet for EAA compliance?
The technical standard is EN 301 549 v3.2.1, the European harmonised standard for ICT accessibility. For mobile apps specifically, Chapter 11 (Software) and Annex A Table A.2 define the applicable requirements.
EN 301 549 builds on WCAG 2.1 Level AA but goes beyond it for non-web software. WCAG was designed for web content. Mobile apps have native UI components, platform-specific gestures, and interaction patterns that WCAG does not fully address. EN 301 549 Chapter 11 covers these, including requirements for:
- Programmatic access to UI elements by assistive technology
- Platform accessibility services (VoiceOver on iOS, TalkBack on Android)
- Closed functionality, where the user cannot install assistive technology
- User preferences for text size, colour, and contrast inherited from OS settings
WCAG compliance alone is not sufficient for mobile app compliance under the EAA. If your accessibility programme is built entirely around WCAG, it needs to be extended to cover the additional EN 301 549 requirements for native software.
Is there a size exemption?
Yes, but it is narrow. Microenterprises that provide services are exempt. The definition is specific: fewer than 10 employees AND annual turnover under €2 million.
This is an AND condition, not OR. A company with 8 employees and €5M in turnover does not qualify. A company with 15 employees and €1.5M in turnover does not qualify. Both thresholds must be met simultaneously.
The exemption applies only to service providers, not manufacturers. If your company manufactures hardware or technology products that fall under the EAA, the microenterprise exemption does not apply regardless of your size.
For most companies reading this, the exemption is unlikely to be relevant. If you have a compliance team, you are almost certainly above the threshold.
What are the European Accessibility Act penalties for non-compliance?
Penalties are set by each EU member state individually. The EAA requires penalties to be "effective, proportionate and dissuasive," but leaves the specifics to national law. Several member states have now published their penalty frameworks:
- Germany. Up to €100,000 per infringement under the BFSG (Barrierefreiheitsstärkungsgesetz). Private actors have sent warning letters under competition law since September 2025. No formal regulator-led fines yet, but the legal mechanism is active.
- Spain. Up to €1,000,000 for very serious infringements under Law 11/2023. Graduated tiers for minor and serious violations.
- Ireland. Up to €60,000 and/or 18 months imprisonment. One of the few member states with criminal penalties.
- France. Up to €7,500 per infraction for legal entities. €15,000 on repeat offence. In November 2025, disability organisations filed injunctions against four major retailers: Auchan, Carrefour, E.Leclerc, and Picard. The approach has been remediation-first, with legal action following where retailers failed to act.
- Netherlands. Up to approximately €103,000. The Dutch ACM (Authority for Consumers and Markets) began carrying out its first audits after a self-reporting window closed in October 2025.
No company has been fined under the EAA yet. But enforcement is clearly underway. The pattern across member states is consistent: regulators are building their enforcement processes, market surveillance is active, and private actors are using competition law as an additional mechanism.
What should I do now?
Three steps:
- Confirm scope. Determine whether your mobile app delivers an in-scope service to EU consumers. Review the service categories listed above against your product. If your app serves consumers in any EU member state in one of those categories, it is in scope.
- Audit against EN 301 549 Chapter 11. Run a structured accessibility audit of your iOS and Android apps against the requirements in EN 301 549 Chapter 11 and Annex A Table A.2. This is not a WCAG audit. It covers native platform accessibility features, assistive technology compatibility, and closed-functionality requirements that WCAG does not address.
- Build a compliance trail. Regulators expect evidence, not assertions. Document your audit findings, track remediation, and publish an accessibility statement. When a market surveillance authority requests evidence of compliance, you need to produce it.
The European Accessibility Act is already being enforced. The question is not whether your app needs to comply, but whether you can demonstrate that it does.
AUDITSU gives your team a guided workflow to audit your iOS and Android apps against EN 301 549 and build the compliance evidence regulators expect. See how it works.