Does WCAG Apply to Mobile Apps?

When you think about digital accessibility, the first thing that comes to mind might be your website. However, digital accessibility also applies to your omnichannel experience — which includes mobile apps. Though originally created for web content, the Web Content Accessibility Guidelines (WCAG) have expanded in scope to include mobile applications, including hybrid and native apps. The guidelines include recommendations on how app developers can make mobile applications accessible to users with varying disabilities. 

Accessibility guidelines for mobile apps were originally introduced in WCAG 2.1 in June 2018. Seventeen new success criteria were introduced for mobile accessibility and increasing accessibility for individuals using various mobile devices to browse the web. 

WCAG 2.2 introduced nine new success criteria for mobile app accessibility, including recommendations for touch targets, responsive design, and gestures. Each of these helps to improve mobile accessibility for users with cognitive, visual, physical, and learning disabilities and builds on the foundation created by WCAG 2.1.

Are Mobile Apps Legally Required to be Accessible?

Yes, in most cases. Under Title III of the Americans with Disabilities Act (ADA), places of public accommodation must be accessible to everyone, particularly people with disabilities. Websites and mobile applications are considered places of public accommodation, meaning they are legally required to be accessible.

However, the ADA does not have technical specifications on digital accessibility. Because of this, the Department of Justice (DOJ) has adopted WCAG as a compliance standard. Organizations that meet the guidelines outlined in WCAG 2.1 Level A and Level AA are considered to be compliant with ADA accessibility requirements. This helps reduce the likelihood of legal challenges, including lawsuits and demand letters, due to a lack of accessibility.

Are Mobile Apps Subject to ADA Lawsuits?

Yes. Mobile apps carry the same accessibility legal exposure as websites. Courts have repeatedly treated apps as an extension of a business's goods and services, which brings them under the ADA.

The path depends on who owns the app. Private businesses fall under Title III. State and local government apps fall under Title II, which now has a compliance deadline of April 26, 2027 for entities serving 50,000 or more people, and April 26, 2028 for smaller entities and special districts. Title III carries no codified technical standard, so courts and the DOJ point to WCAG 2.1 Level AA as the practical benchmark.

Most claims trace back to the same barriers. An app that a screen reader cannot interpret, such as controls without accessible labels or actions that only work through complex gestures, creates the kind of access failure that leads to a demand letter. If your business receives one, document your current accessibility state and coordinate with legal counsel before responding.

You can learn more in our guide to navigating ADA compliance and website accessibility lawsuits.

Stylized web browser on a laptop showing a checklist with the accessibility icon at the top.

Mobile App Accessibility Checklist

To help you meet WCAG accessibility standards, consider using the checklist below as a starting point. It’s important to note that incorporating these features won’t make your mobile app or mobile site 100% compliant — additional accessibility testing is needed to ensure complete compliance.

Color Contrast

WCAG 2.2 Level AA guidelines require text to have a color contrast ratio of at least 4.5:1 and larger text to have a 3:1 ratio. Using the appropriate color contrast ensures disabled users (including those with visual impairments or disabilities) can distinguish between web elements and understand the app’s content. A color contrast checker can help you strike the right balance.

Keyboard Navigation

Users should be able to navigate your mobile app using just a keyboard. The tab order for the page should also be logical and intuitive to ensure a good experience.

Alternative Text

All images, including decorative images, should include alternative text (alt text). This ensures users with visual disabilities (i.e., blindness, low vision, color blindness, etc.) have context around the image and why it’s included on the page.

Headings

Headings should be used appropriately to create a logical content hierarchy. More simply, headings should provide information about the structure of a page and the user journey.

Target Size

WCAG 2.2 Level AA requires touch targets to be at least 24 x 24 pixels, or to have enough space around them that a 24 pixel circle centered on each one doesn’t overlap with another target. 

None of these items can be confirmed just by looking at a design file. Each one has to be checked and tested on the built app, which is exactly what mobile accessibility testing covers.

For example, AudioEye performs an in-depth expert audit of your mobile applications to identify WCAG violations. All violations are shared in a detailed report so you can prioritize which accessibility errors should be resolved first. We also rely on our A11iance Community to test mobile apps and report accessibility roadblocks.

Create WCAG-Friendly Mobile Apps with AudioEye

Mobile accessibility isn't a side project. It's the standard your users expect, and WCAG is the benchmark that gets you there. Getting there consistently, across every screen and update, takes more than a one-time fix. It takes the right approach.

AudioEye is the only accessibility provider that combines AI-powered automation with expert Custom Fixes at scale. That approach reaches approximately 97% issue coverage, work that automation alone or a consulting firm alone can't match. Our Mobile App Audits test your iOS and Android apps against WCAG criteria, and our team of experts writes and validates fixes for the issues automation can't resolve on its own.

Don't wait for a complaint or a demand letter to tell you where your mobile app falls short. Get a Mobile App Audit from AudioEye and start fixing issues before they find you.