ADA and mobile apps: what the rule covers

In brief

The Title II web rule covers mobile apps as well as websites. It defines them as software applications that are downloaded and designed to run on mobile devices, such as smartphones and tablets. The standard is the same as for the web: WCAG 2.1 Level A and Level AA.

What is covered

• Apps the entity builds itself.
• Apps provided through contractual, licensing or other arrangements. DOJ says a third-party app an entity provides under a contract or license must also meet the standard.
• Conventional electronic documents inside an app, which follow the same exceptions as on the web.

How to test an app

• Screen readers: VoiceOver on iOS and TalkBack on Android. Go through every main flow.
• Text size: Set the largest text size in the system settings and check nothing is cut off.
• Alternative input: Test with a keyboard or switch device where the platform supports it.
• Automated checks: Use the platform inspectors. They find only some problems.

The checklist pages include iOS and Android code examples. The mobile apps page explains where to begin.

What to do

• Add every app you provide or make available to your inventory, including vendor apps.
• Test the main flows with a screen reader on both platforms.
• Ask vendors for accessibility information before you buy or renew.

Common mistakes

• Testing the website and forgetting the app.
• Assuming a vendor's app is the vendor's problem. It is still provided by you.
• Using only automated scanners.

Sources

• 28 CFR Part 35, Subpart H: Accessibility of Web Information and Services (eCFR), opens in a new tab
• 28 CFR 35.104: Definitions (eCFR), opens in a new tab
• First Steps Toward Complying with the Title II Web Rule (ADA.gov), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official ADA statute and regulations, and ask a lawyer how they apply to you.