Much of the attention and energy around digital accessibility surrounds ADA compliance for websites. Even for companies that devote significant resources to accessibility efforts, mobile apps are often an afterthought. But they shouldn’t be!
In fact, one of the most important digital accessibility legal decisions concerned the Domino's Pizza delivery mobile app. In late 2019, the Supreme Court declined to hear an appeal of Robles v. Domino, which left in place the Ninth Circuit’s decision that both websites and apps are subject to the ADA. In that case, a blind customer had sued Domino’s because he was unable to use the delivery website or mobile app to order a pizza.
The Supreme Court’s actions have led to an explosion of surf-by ADA accessibility lawsuits and expanded interest in digital accessibility testing and remediation. In line with that trend, the number of lawsuits specifically targeting mobile apps grew to nearly 20% of the total in 2020.
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What are the requirements for mobile app ADA compliance?
One major source of frustration to businesses and organizations trying to remain in compliance with the ADA is that the government has still not published any standards for digital accessibility. For web, the courts have generally defaulted to using the Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG), which do not specifically address mobile apps (or other types of applications such as smart TVs).
Our recommendation is to use the WCAG as your north star as you incorporate accessibility into your app’s experience. For the most part, the WCAG checkpoints translate fairly well to mobile apps. However, you should be aware that they can require a little bit of interpretation as the WCAG is written around HTML. W3C has published some supplementary draft guidelines for mobile and the latest version of WCAG directly highlights some mobile considerations (that apply both for web and apps).
In addition, Apple has published iOS accessibility design guidelines and UIKit accessibility documentation while Google has produced an Android accessibility guide. While these aren’t exhaustive sets of accessibility requirements, they can serve as a useful supplement as well as a source of information on how you can leverage built-in features in the mobile operating systems and code frameworks to improve accessibility.
What is the best way to make your mobile app accessible?
The short answer is: the best way to make your mobile app accessible is to build it that way the first time. In addition to the guides published by iOS and Android that we mentioned above, there are quite a few accessibility resources available for mobile app developers including some automated testing.
Once your app is complete, there are no easy options for automated testing. Mobile apps run compiled code, which means that unlike websites, there are no automated testing platforms that can be used to identify accessibility violations without testing manually. This is why our best advice is to start thinking about accessibility as early as possible in your development process.
Consider web or hybrid apps
Most mobile apps are built as native apps; these are custom coded for each mobile OS. But there is another option. It is possible to build a hybrid web app, which essentially encodes a website (or an app built using web coding languages like HTML, CSS, and Javascript) into an app wrapper. This process also tends to be far less expensive for simpler apps because the app can be built by a less specialized developer and the code can be reused on both the iOS and Android version of the app. The downside is that hybrid web apps tend to have slower performance and the costs can quickly rise the more customization is required.
That said, if your mobile app is relatively simple, building a hybrid web app can allow you to take advantage of many web-specific automated accessibility tests. Identifying and fixing accessibility issues also tends to be simpler as web accessibility guidelines are far better documented than the mobile app equivalents.
In any case, even many native apps use web wrappers for at least small portions of the app. For example, in most apps, the privacy policy or other content-heavy sections will display web elements within an app wrapper. At minimum, you should take advantage of web tools to review these specific app sections.
Mobile app ADA audits
Silver linings: mobile app audits are more cost effective
If you are only first thinking about accessibility after your app has already been built, you will need to start with an audit. The good news is that mobile app audits tend to be far more reasonably priced than an equivalent web audit. The reason is that there are fewer versions of the app that you will need to test. You might test a website on Chrome, Safari, and Firefox — and that’s just on MacOS. You’ll also need to test Chrome, Firefox, and Edge in Windows, Safari in iOS, and Chrome in Android. In addition, Windows users are split between the NVDA and JAWS screen readers while MacOS users tend to rely on Voiceover.
In contrast, Android has the Talkback screen reader built into the operating system while iOS has Voiceover. The app is a single environment, which means that you don’t need to test across browsers. In short, you can complete a comprehensive mobile app audit by testing in only two environments (as compared to 8-12). If you want to be very thorough, you can test previous versions of the mobile OS, but either way, you should come out way ahead.
Mobile app audits are lower pressure
Most companies pursue mobile app accessibility in response to legal risk (or even a lawsuit) or as a prerequisite for signing a government contract. Since mobile apps cannot be tested for accessibility automatically, this means that you are less likely to be threatened by a surf-by serial plaintiff. However, the flipside is that if you do get sued, it is likely to be a legitimate case filed by a customer (or attempted customer) who was unable to use your mobile app due to accessibility violations. Our advice is to take advantage of the relaxed timing constraints to do things the right way without cutting any corners.
Mobile app accessibility is more persistent
The final silver lining when it comes to mobile app accessibility is that there is far lower risk of accessibility decay. Unlike websites where both content and code can change constantly, most apps have more controlled processes for release or deployment of a new version of the app. While it is still possible to introduce new accessibility issues via your data source or coding bugs, you can exert far more control and feel more confident that once your app is accessible, it will stay that way for a while.
Prioritizing high impact fixes
In order to make your app fully ADA compliant, you have to take care of everything; even one violation of a WCAG guideline renders the app noncompliant. However, you do have control over how you navigate your accessibility journey and you should take advantage of the ability to release iterative improvements. Your goal should be to find the highest impact improvements to the user experience for those with disabilities; this should also have the added benefit of reducing your legal risk.
Here are some accessibility issues you should consider tackling first:
- Replacing low-contrast color combinations with ones that are more readable for those with low-vision. For non-text elements, the minimum ratio is 3:1 while text elements should have a ratio of at least 4.5:1.
- Avoid using images of text
- Any image-based elements on your app (such as buttons) should have alternative text if they are not purely decorative
- The app should be readable and operable when zoomed in
Access Armada can help you become ADA compliant
Not sure where to start? It’s best to first initiate a conversation with your app developers to get a better sense of how much (or little) they incorporated accessibility into their development process. Whatever the answer, you’ll need to work closely with them to address any remaining accessibility issues.
If your developers can’t vouch for the app’s current accessibility status, reach out for a free strategy session to build a custom accessibility plan for your mobile apps. We can identify some of the low hanging fruit and our more comprehensive audits can identify all accessibility issues along with recommendations for remediating each one in order of severity and impact.
