Yes, an app can fall under the European Accessibility Act, and in practice the same technical requirements apply as for a website: EN 301 549, or WCAG 2.1 level AA. What matters is not whether something is a website or an app, but whether you use it to provide a service to consumers. A shopping app of a webshop, a booking app for a service, or an app through which customers log into their account, generally fall under this.
Whether your specific app counts depends on a few concrete points: who the user is, what the app does, and how large your business is. An app used exclusively by your own employees falls outside the directive, as it is aimed at services to consumers. An app that customers use to order, book, or manage their account falls under it, unless you qualify for the exemption for micro-enterprises. in a few questions to see if this applies to you provides an initial indication of this without an account.
Consumer service is the core
The directive concerns services offered to consumers. This distinction is important: an app intended exclusively for business customers, in a purely B2B relationship, falls outside the scope as formulated for consumer services. Once an app also addresses individuals, or once the service behind it is a consumer service, this criterion does count. If you are uncertain about the precise scope of a concrete situation, the legislation itself, or a legal advisor, is the appropriate place to check; we describe the main line here, not a ruling on your specific case.
A second point is the type of app. Native apps for iOS and Android fall under the same technical standard as websites, EN 301 549, which explicitly includes software. This means that keyboard operation, screen reader support, colour contrast and clear labels on form fields in an app are just as relevant as on a web page. A web app that runs in the browser is assessed in practice in the same way as a regular website.
The exemption also applies here
The exemption for micro-enterprises works with apps in the same way as with websites: fewer than ten employees and a turnover of at most two million euros, and this applies to the business offering the service, not the app itself. Both conditions must fit together. A small business that has an app developed by an external agency remains the service provider, and the size of that own business is decisive, not that of the developer.
What is often overlooked
Businesses that have already had their website tested sometimes forget that the associated app deserves a separate assessment. A shopping cart and checkout step in the app may be technically structured differently than the same step on the website, with its own buttons, its own forms and its own navigation structure. A login screen in an app also often has different labels and error messages than the web version, and these are then tested separately. Those who wish to read more about this in each situation will find it set out in the knowledge base with topics per situation.
Another point that comes up regularly: an accessibility widget or overlay built into the web version usually does not carry through to the native app, and in any case does not meet the underlying requirements. This applies to apps just as much as to websites.
How you check this for your situation
The free scope check answers whether your business and your service fall within the directive, including the exemption for micro-enterprises, and refers you to where this is located in the official text. For an app that goes further than core pages, such as a complete order or login flow, a more extensive test is required; what this entails and how it differs from the free quick scan is set out clearly in the page explaining what a full scan adds. Common borderline cases, such as apps with both business and private users, can also be found among the questions that come up more often.
When in doubt, simply start with the free scope check. It takes a few minutes, requires no account, and tells you straightforwardly whether the directive applies to your app and business.