What The European Accessibility Act (Might) Mean for Mobile Development

Rob Whitaker
Jun 24 · 6 min read

The European Accessibility Act or EAA is due to become law in Europe later this year, and it defines some specific requirements for mobile. Its the first accessibility legislation that I’m aware of, anywhere, that explicitly covers mobile apps.


The European Union has been working on standardising accessibility legislation across Europe since 2012. The ultimate aim is to both improve the experience for those who need to use assistive technology, but also to simplify the rules business need to follow on accessibility. Years of discussions and consultations have led to the European Accessibility Act, written in 2018. The act covers a range of requirements for, amongst other channels, mobile.

While the EAA doesn’t blanket cover every category of app, the net is pretty broad. The act covers any apps sold or in use within the European Union that fall into these categories. So even if your business is not part of the Euro Zone if your app is available on an app store any country that is a member, then the act applies to you. So, if you’re in the business of making mobile interactions, you’ll need to prepare. Fortunately, both Apple and Android provide many of the tools required to conform to the law at a system level, meaning you’ll likely be a long way towards complying already.

As with any new law, until tested in the courts, it is somewhat open to interpretation. Most importantly, I’m not a lawyer. I’m a mobile developer with a keen focus on accessibility. This post makes up my own thoughts about how I would try to follow the law and will undoubtedly contain some factual inaccuracies. I’ve not included everything but focussed on the areas I think are most useful to mobile developers. If you believe this new legislation may regulate your app, I’d recommend reading the act yourself. Of course, you’ll need to get some legitimate legal advice.

Apps Types Covered

The EAA explicitly covers mobile apps in certain areas. While this doesn’t cover all apps, it’s safe to say these categories make up a significant section of mobile apps available.

Transport

Any app related to publicly available transport including air, bus, rail and ‘waterborne’ transport. The act doesn’t explicitly state taxis or ride sharing. Arguably they we should include these under the definition of ‘passenger transport services.’

Banking

Any app that provides banking services. The phrase ‘banking services’ specifically, suggesting the EU would apply this rule not only to banks themselves. Also broadly to apps that use open banking to access other accounts or other banking related services.

e-commerce

Any app that allows for digital purchases of either digital or physical goods or services. This clause will be the one that covers the majority of apps. But the requirements here are not as detailed as the more specific domains above.

Requirements for All Apps & Websites

Alternatives to Non-Text Content

If you present content in video form make sure your video features subtitles or closed captioning. Provide a transcript for any content presented in video or audio format. If you present text content in an image or as part of a video, add an accessibility label or subtitles that a screen reader can access.

Make Content Available to Screen Readers

This requirement covers two points from the act. Firstly:

Information content shall be available in text formats that can be used to generate alternative assistive formats to be presented in different ways by the users and via more than one sensory channel.

Also:

consistently … [present content] in a way which facilitates interoperability with a variety of user agents and assistive technologies.

My understanding of these paragraphs is that any text-based content should be accessible to screen readers (VoiceOver and TalkBack). Screen reader users make up by far the most significant constituency of assistive technology users. Also, both OSes use the techniques for screen readers to allow support for other assistive technologies. This means if you get screen readers right you’ll find other assistive technology will work well too.

For the most part, both Android & iOS built-in screen readers will do a great job of making the text available for the user. Even making guesses at text included in images where needed. However, at times it can be easy to cause unexpected behaviour from screen readers. From elements out of order to missing elements. Sometimes screen readers will read elements when they are not present on the screen. The best way to see if you need to make any changes here is to test with your devices screen reader enabled.

Requirements for Transport & Banking Apps & Websites

Flexible Magnification

It is unclear from the act whether magnification applies to simple screen magnification or to allowing magnification of text sizes. I suspect it would be simple to argue that screen magnification fulfils this requirement if you’re looking to satisfy the minimum needed by the law. Screen magnification, however, isn’t a great experience for your customer, as it cuts context and reduces discoverability. Because of this, I’d recommend supporting dynamic text sizes regardless of the true meaning of the law.

Screen magnification is a system feature available on both platforms (Android, iOS) that requires no developer changes. Dynamic text sizes need a little more consideration. It’s worth giving some UX thought to how a screen will look and function when the screen appears with the largest text. At times you will need to make decisions on compromises to design with accessibility text sizes.

iOS Developers will need to adopt the use of iOS’ built-in text styles and use the adjustsFontForContentSizeCategory property for each content label. For Android, you should use SP sizes for text that scale from your standard size to match your customer’s device settings.

Flexible Contrast

In regular use, your text to background contrast ratio should be 4.5:1 for most text. With this setting enabled, you should look to have a contrast ratio of 7:1. This might need some UX decisions on what colours to use.

iOS provides an accessibility setting to increase contrast. As a developer, you can listen to UIAccessibility.isDarkerSystemColorsEnabled to see if you need to make UI changes based on this setting. I’d also recommend listening to UIAccessibility.isReduceTransparencyEnabled if you’re making use of transparency or blur in your app. If your user has this setting enabled be sure to provide an alternative. The alternative doesn’t have to be a solid colour, a reduced alpha or increased blur may be enough. A technique Apple make use of on SpringBoard is to use a solid colour that has a tint of the colour underneath.

iOS SpringBoard with standard settings
iOS SpringBoard with reduced transparency enabled

Android does provide a High Contrast Text accessibility setting. Unfortunately Android provide no developer documentation on what this does, or how developers can leverage it. As a result supporting flexible contrast may require you to add a contrast setting within your app.

Alternative Colour

Alternative colour is potentially the caveat that may need the most work to conform to. This rule probably needs someone more skilled than me in reading legislation to precisely know what this clause means.

It’s possible that the customer’s device’s built-in colour filters will fulfil this requirement. The system features of inverting colours (Android, iOS), switching to greyscale, or adding a filter (Android, iOS) to the screen would have this effect. However, its possible the act expects you to allow customers to change your main body text colour. I’m not aware of a system framework on either platform to allow for simple switching of body text colours in this way. A global skinning solution for your app and some UX decisions may be needed.

The text says only ‘provide for an alternative colour to convey information.’ I’ll let you draw your own conclusion about which option would allow your app to fulfil the requirement.

Alternative to Fine Motor Control

Both iOS and Android support control by external switch devices or by using the device’s screen or buttons as a switch. Providing your app works as expected with screen readers, you’ll probably find switch control works fine, but it’s worth testing with this enabled.


Have any thoughts on what the EAA might mean for your apps and how you intend to follow the legislation? please let me know below.

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Rob Whitaker

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iOS Engineer at Capital One.

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