Does the accessibility law also apply to my app?

Apps and checkout environments are subject to the same law

Yes, the European Accessibility Act also applies to a checkout app, in the same way as it does to the website. The directive looks at the service being offered — in this case an e-commerce service — and not at the channel through which that service is delivered. Whether a customer orders a product via a browser on a laptop or via a native app on a phone makes no difference to whether the law applies. This means that a checkout app, like a webshop, has EN 301 549 as its standard, in practice WCAG 2.1 level AA, and this applies to the entire journey within the app: browsing products, the login screen, the shopping cart and the payment step.

For apps, the emphasis is slightly different than for a website: EN 301 549 has, alongside the requirements for web pages, a separate section on software in general, and that section is written to apply to native apps as well, regardless of the underlying technology. The micro-enterprise exemption works the same way as for a website: an enterprise with fewer than ten employees and an annual turnover of up to two million euros that provides services falls outside the scope, regardless of whether that service is delivered via a website or via an app. This is something the scope check takes into account.

Why this is in article 2 and the standard

The directive lists e-commerce services as one of the services that fall within its scope (article 2, paragraph 2, point (f) of Directive (EU) 2019/882), without limiting the channel to websites; a native app that performs the same ordering function is an implementation of that same service. EN 301 549 V3.2.1 elaborates on this with a separate section on software, which explicitly also applies to applications outside the browser, alongside the sections that specifically address web content.