App accessibility requirements stopped being a design preference on 28 June 2025. Since that date the European Accessibility Act has applied to any business that sells online, banks, carries passengers, or provides communications, media or e-book services to consumers in the EU, wherever that business is based, and the member states back it with fines of up to €100,000 in Germany. At home, the Equality Act 2010 has required anyone providing a service to the public to make reasonable adjustments for disabled people, as a group and in advance, for fifteen years. Most apps would fail the test today: WebAIM found detectable accessibility failures on 95.9 per cent of the top million home pages in February 2026, and when the UK Government tested 21 public sector mobile apps, none was fully compliant.
The cheap time to fix that is before the first screen is designed.
What are the app accessibility requirements for a UK business?
Two laws apply to a private business, and a third if you are a public body.
Law | Who it covers | In force | Standard | Enforcement |
|---|---|---|---|---|
European Accessibility Act, Directive 2019/882 | Anyone offering e-commerce, consumer banking, passenger transport, electronic communications, media access or e-books to consumers in the EU, wherever the business is based | Services from 28 June 2025; earlier contracts run on to expiry, no later than 28 June 2030 | EN 301 549, the European standard built on WCAG | National authorities and fines; consumer and disability-body actions |
Every service provider in England, Wales and Scotland, no size exemption | Since 2010 | None named: "reasonable adjustments", including information in an accessible format | Claims by individuals in the county court or sheriff court | |
UK public sector websites and apps | Apps since 23 June 2021 | GDS monitors, the EHRC enforces, and a failure counts as a failure to make a reasonable adjustment | Cell |
The EAA's reach is the part UK firms miss. Article 3 defines a service provider as anyone who "makes offers to provide such a service to consumers in the Union", with no requirement to be established there, and e-commerce means any website or app used "with a view to concluding a consumer contract". A Bedford retailer shipping to Dublin is in scope. Microenterprises providing services, meaning fewer than ten staff and under €2 million turnover, are exempt. Everybody else has to design the service to the requirements, publish how it meets them, and tell the national authority when it does not.
The Equality Act has no size exemption at all, and the duty is owed to disabled people as a class before anyone complains. Schedule 2 says the reference to a disabled person in the reasonable-adjustment duty "is to disabled persons generally". You do not get to wait for the first screen-reader user to write in.
What standard does an app have to meet?
WCAG 2.2 Level AA, and build to it now even though the European paperwork is a few months behind. The Web Content Accessibility Guidelines 2.2 became a W3C Recommendation on 5 October 2023 and carry 86 success criteria; Level AA means meeting the 55 at levels A and AA. Nine criteria are new in 2.2, and most of them are about phones: target size, alternatives to dragging, no re-entering information, and login that does not depend on transcribing a code.
The European standard, EN 301 549, was republished as version 4.1.1 on 2 September 2026 and now points at WCAG 2.2 AA. It becomes the harmonised standard for the EAA once the European Commission cites it in the Official Journal, which Ireland's National Disability Authority expects on 16 December 2026. WCAG 3 is a working draft, not a deadline. Apple's Accessibility Nutrition Labels on the App Store are voluntary today; Apple has said they will become a condition of submission, with no date given.
Would your app pass?
Probably not. WebAIM's 2026 analysis found an average of 56.1 detectable errors per home page, up 10.1 per cent on 2025, and automated tests catch only a minority of failures. Low-contrast text was on 83.9 per cent of pages, missing alternative text on 53.1 per cent, unlabelled form fields on 51 per cent. An app ships with the same three faults when nobody owns accessibility.
The UK Government's monitoring of public sector bodies between January 2022 and September 2024, organisations that had been legally bound for years and knew they would be tested, found 29,787 issues across 1,203 websites and 21 apps. In detailed testing none of the 52 websites and none of the 21 apps was fully compliant, and 310 cases were recommended for enforcement. A University of Washington study of 312 Android apps over 16 months (2022, a landmark) found missing labels on 55.6 per cent of image-based elements, and that the failure rate did not improve with download numbers. The people affected are on phones: 91.3 per cent of screen reader users in WebAIM's 2024 survey use one on a mobile device.
What does it cost to ignore?
Three things: fines you can now be charged, sales you are already losing, and a legal claim with no ceiling. Ireland's regulations carry fines of up to €60,000 or 18 months in prison on indictment; Germany's go up to €100,000; Spain applies its disability-law scale of up to €1,000,000. No EAA fine or court order had been confirmed anywhere by October 2026. The first cases, brought by French disability associations against four retailers, reached court in May 2026, and the first ruling went Auchan's way on a turnover threshold rather than the merits. The exposure is building ahead of the enforcement.
The sales case is older and larger. There are 16.7 million disabled people in the UK, 25 per cent of the population (DWP, March 2026). The Click-Away Pound survey of 2019 found 69 per cent of disabled users with access needs leave a site that puts barriers in their way, modelled the spend that went elsewhere at £17.1 billion, and found only 8 per cent ever tell the business. UK Government research published in July 2025 found technology the most challenging sector for disabled consumers across the whole buying process. Silence from disabled customers means they left.
Under the Equality Act there is no fining regulator; a disabled person brings a claim, and the cases that exist settle before a hearing, under confidentiality.
Why is retrofitting more expensive than building it in?
Because the decisions that fail WCAG are made once and copied to every screen. The colour palette, the component library, the navigation structure, the form pattern and the login flow are set in the first fortnight of design, and every screen inherits them. Fix contrast, target size or focus order after launch and you are touching the whole app, retesting it with VoiceOver and TalkBack, and resubmitting it. No primary research puts a multiplier on that difference, and the agency figures in circulation are guesses.
The EAA adds a paperwork cost to lateness. The only way out of a requirement is a documented assessment showing a "disproportionate burden" or a "fundamental alteration", kept for five years. Writing that assessment for a decision you could have made for nothing at the start is the expensive half.
On our builds, WCAG 2.2 AA goes into the design brief, which means screen reader labels, text that scales with the phone's settings, contrast and touch targets checked in design review, and a test pass with the assistive technology switched on before release. It is also a discovery question, because an app selling to consumers in Dublin is a different legal object from an internal tool in Bedford, and regulated-sector work taught us to settle that before pricing.