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Accessibility in mental-health apps: the law and the details

The European Accessibility Act, Irish public-sector rules and WCAG for mental-health apps, plus the design details that matter most.

By Myndgard Limited

Banner reading: Accessibility in mental-health apps

Accessibility in a mental-health app is not a separate feature for a small group of users. Disability and mental health overlap heavily in higher education. In the 2023/24 academic year, 22,519 students were registered with disability support services in Irish higher education institutions, 8% of the student body, according to AHEAD. A mental health condition was the second most common category, reported by 21.2% of those students, after specific learning difficulties at 38.8%. ADHD (15.2%) and autism (12.3%) were also common.

So a student opening a counselling app may be anxious, tired, using a screen reader, or finding it hard to concentrate, and possibly several of these at once. This article covers the legal picture in Ireland and the design details that make the most difference.

The European Accessibility Act: in scope or not?

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. In Ireland it was transposed by S.I. No. 636 of 2023, and the Competition and Consumer Protection Commission publishes guidance for businesses.

The EAA does not cover every app. It applies to a defined list of products and services: among the services are electronic communications, access to audiovisual media, elements of passenger transport, consumer banking, e-books and e-commerce. Health and wellbeing services are not on the list as such.

The category most likely to matter for an app is e-commerce, which the Irish Regulations define as services provided at a distance through websites and mobile apps "at the individual request of a consumer with a view to concluding a consumer contract". A wellbeing app that sells subscriptions directly to the public is likely to be in scope on that basis. An app provided free to students under a contract between a vendor and a university is a different arrangement, and in our reading is unlikely to be an e-commerce service. The Regulations also exempt microenterprises, meaning fewer than 10 staff and turnover or balance sheet of no more than €2 million, from the requirements for services.

That is a reading of the text, not a ruling, and each product's position depends on how it is sold. Vendors should be able to tell you whether they consider themselves in scope and why.

The rules that clearly apply to universities

For universities, the more direct obligation predates the EAA. Ireland's public-sector accessibility Regulations, S.I. No. 358 of 2020, require public sector bodies to make their websites and mobile apps perceivable, operable, understandable and robust. They have applied to mobile apps since 23 June 2021. Public sector bodies must publish an accessibility statement for each, and the National Disability Authority monitors compliance.

The definition of "public sector body" includes bodies governed by public law, which is likely to cover publicly funded universities. The Regulations exclude third-party content that is "neither funded nor developed by, nor under the control of" the public body. An app a university pays for and offers to its students is therefore arguably within the university's obligations, so it makes sense to write accessibility requirements into procurement.

Which standard?

Content that meets the harmonised standard is presumed to comply. That standard is EN 301 549. The version currently cited, V3.2.1, incorporates WCAG 2.1 at Level AA for web content. A final draft of V4.1.0, published by ETSI in June 2026, moves to WCAG 2.2 and maps its requirements to the EAA.

WCAG 2.2 has been a W3C Recommendation since October 2023 and is backwards compatible: content that meets 2.2 also meets 2.1. Designing to WCAG 2.2 AA now is the practical choice.

The details that matter in a mental-health app

Calm, predictable screens. The W3C's guidance on cognitive and learning disabilities notes that people experiencing stress or mental health conditions can have difficulty focusing, fatigue and reduced memory. Its design objectives include clear content, helping users focus, not relying on memory, and making help easy to find. One task per screen, consistent navigation and no time pressure help everyone.

Respect reduced motion. Animation can cause dizziness and nausea, particularly for people with vestibular disorders. WCAG's Animation from Interactions criterion asks that non-essential motion can be turned off, and recommends honouring the operating system's reduce-motion setting. It is a Level AAA criterion, but it is easy to meet and especially relevant to someone who is already anxious.

Large, well-spaced tap targets. WCAG 2.2 added Target Size (Minimum) at Level AA: targets of at least 24 by 24 CSS pixels, or enough spacing. Questionnaire answers with four close options are exactly where this matters, especially for someone with a tremor or using their phone one-handed.

Accessible sign-in. WCAG 2.2 also introduced Accessible Authentication (Minimum) at Level AA: signing in should not depend on a test such as remembering a password or solving a puzzle, unless there is an alternative or something to help, such as support for password managers and copy-and-paste.

Plain language. Questionnaire items such as those in the PHQ-9 have fixed, validated wording that should not be changed. Everything around them, from instructions to results to safety messages, can be written in short sentences and everyday words.

Screen readers and text size. Every control needs a meaningful label, the reading order must make sense, and layouts must hold up when a student increases the system text size. Charts of mood or scores need a text equivalent. Test with VoiceOver and TalkBack, not just automated checkers.

Colour is never the only signal. Severity bands and risk indicators should use words as well as colour, with sufficient contrast in both light and dark modes.

In practice

For counselling services choosing a digital tool:

  1. Ask for the vendor's accessibility statement and the standard it is measured against (ideally WCAG 2.2 AA).
  2. Ask whether testing includes real screen-reader use on iOS and Android.
  3. Check that reduced motion, larger text and dark mode are respected.
  4. Put accessibility requirements in the contract, given your own obligations under S.I. 358 of 2020.
  5. Invite students registered with your disability service to try it before launch.

This article is general information, not legal advice.

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