Mobile Accessibility Requirements

Kiosk and Website Requirements
June 16, 2015
Wounded Warrior Project
June 30, 2015

Usually, mobile applications are generally covered by the same standards for access by people with disabilities that apply to non-mobile software and web applications. Applicable U.S. laws such as the Twenty-First Century Communications and Video Accessibility Act (CVAA), Section 508, and the Americans with Disabilities Act (ADA) apply in different ways. Although it is normally directed by the same set of regulations, it is important to know and understand the requirements for mobile devices and applications.

The technical and functional requirements of Section 508 such as Section 1194.21 Software Applications and Operating Systems, Section 1194.22 Web-based Intranet and Internet Information and Applications, and Section 1194.31 Functional Performance Criteria can be applied to mobile content. While these standards do specifically state anything about mobile applications and the requirements, the requirements cover the general accessibility requirements that are relevant to mobile applications and mobile device accessibility.

Regarding organizations that must be ADA complaint, accessibility of mobile devices and applications should follow Web Content Accessibility Guidelines (WCAG) 2 standards including multimedia access (captioning and audio descriptions).


WCAG 2 does not specifically address mobile devices and applications, however, the principles and success criteria outlines in WCAG 2 are relevant to mobile applications. The sufficient techniques and known failures for WCAG 2 don’t specifically address mobile applications, although sufficient techniques and failures are non-normative information and criteria for mobile devices and applications could be created to map WCAG success criteria. The World Wide Web Consortium (W3C) did create Mobile Web Best Practices for mobile web apps, however, these best practices are not accessibility specific even though they do include guidance that promotes accessibility across all platforms. The most relevant guidelines are those included in the WCAG 2 set of public standards that should guide mobile application development to ensure accessibility. Additionally, the Web Accessibility Initiative (WAI) created a W3C guideline document titled User Agent Accessibility Guidance 2.0; the guidelines provided in this document are useful for addressing the accessibility of any mobile application.

The CVAA Rulemaking and Order from October of 2011 addresses guidelines on what performance objectives must be met for advanced communication devices and applications. These types of objectives included access without vision, with low vision, without hearing, without color perception, with limited manual dexterity, without speech, etc. The objectives also address availability of information without requiring vision, hearing, etc. These functional objectives are inline with the core principles of WCAG 2 guidelines and Section 508. Thus, WCAG 2 guidelines and Section 508 standards are a logical starting point for mobile application development under CVAA.

Mobile applications and devices may be subject to one or more accessibility standards. Moreover, the main international standards for accessible web content the WCAG 2 Guidelines are a good foundation for ensuring mobile apps are accessible to people with disabilities. As requirements for the ADA are created by the DOJ, more rulemaking is likely to be made under the CVAA in the form of more specific standards and they’re likely to emerge around mobile content.