WCAG-EM 2.0 Draft Expands Beyond Websites to Mobile Apps and Digital Products

The W3C released the first draft of WCAG-EM 2.0, and it's a bigger deal than the quiet announcement suggests. For the first time, we have a standardized methodology for evaluating accessibility across mobile apps and digital products—not just websites. This means disabled users can expect more consistent access across all digital touchpoints.
WCAG-EM (Web Content Accessibility Guidelines Evaluation Methodology) has been the gold standard for systematic accessibility testing since its first release. Version 1 gave us a structured, repeatable process for evaluating websites against WCAG 2 guidelines. But it was limited to web content. Now WCAG-EM 2.0 extends that same rigorous approach to mobile applications, desktop software, and other digital products.
What This Means for Development Teams
Here's the reality most dev teams face: they're building across multiple platforms—responsive web apps, native iOS and Android apps, maybe some desktop software. Each platform has its own accessibility considerations, testing approaches, and evaluation criteria. Teams often end up with inconsistent accessibility practices across their product suite, which means disabled users get different levels of access depending on which platform they use.
WCAG-EM 2.0 could solve this fragmentation. Instead of cobbling together different testing methodologies for each platform, teams get one comprehensive framework that ensures consistent accessibility across their entire digital ecosystem. This means disabled users can expect the same level of access whether they're using your website, mobile app, or desktop software.
The methodology maintains the same five-step structure that made the original so practical:
- Define evaluation scope—now expanded to include app functionality, user flows, and platform-specific features
- Explore the target—understanding how users navigate across web and mobile interfaces
- Select representative samples—crucial for apps with dynamic content and complex user journeys
- Audit the selected samples—applying WCAG success criteria consistently across platforms
- Report evaluation findings—standardized documentation that demonstrates commitment to equal access
Mobile App Accessibility Testing Gap
This expansion addresses a real problem in ensuring equal access. While Section 508 and various state accessibility laws increasingly cover mobile applications—recognizing that disabled people need access to digital services regardless of platform—there hasn't been a standardized evaluation methodology. Teams have been adapting web-focused approaches or creating their own testing protocols, leading to inconsistent accessibility across platforms.
The Pacific ADA Center regularly fields questions about mobile app accessibility, especially from government agencies working to meet their Title II obligations to provide equal access to disabled citizens. Having a W3C-endorsed methodology gives organizations confidence they're conducting thorough evaluations that truly serve disabled users.
For development teams, this standardization is significant. It means accessibility testing becomes more predictable and systematic. Instead of wondering "are we testing this thoroughly enough to serve our disabled users?", teams have clear guidance on scope, sampling, and evaluation criteria.
Implementation Reality Check
Expanding from websites to apps isn't just about methodology—it's about capacity to properly serve disabled users across all platforms. Web accessibility testing typically involves automated tools, manual keyboard navigation, and screen reader testing. Mobile app evaluation adds platform-specific assistive technologies, gesture-based interactions, and device-specific considerations.
Teams will need to level up their testing environments. That means iOS devices with VoiceOver, Android devices with TalkBack, and familiarity with platform accessibility APIs. The methodology is only as good as the team's ability to execute it properly and understand how disabled users interact with their products.
The good news is that WCAG-EM's structured approach makes this capacity building more manageable. Instead of trying to learn "everything about mobile accessibility," teams can focus on the specific evaluation steps and gradually build expertise in serving disabled users across all platforms.
Strategic Timing for Digital Accessibility
This draft comes at a crucial moment for equal access. The Department of Justice has been increasingly active on digital accessibility enforcement, with several high-profile mobile app cases in recent months. These enforcement actions reflect the reality that disabled people need equal access to digital services regardless of platform. Organizations are looking for clear guidance on how to evaluate whether they're truly providing equal access across all digital touchpoints.
WCAG-EM 2.0 provides exactly that—a methodology that works whether you're a university ensuring students can access your portal, a retailer making sure customers can use your e-commerce app, or a government agency providing accessible citizen services.
According to the W3C, the draft is open for public comment through email to wai@w3.org or via GitHub. This is the time for practitioners to weigh in on whether the methodology works in real-world development environments and truly serves disabled users.
What's Next for WCAG-EM 2.0
For teams already using WCAG-EM 1, the transition should be relatively smooth—the core methodology remains the same, with expanded scope and updated guidance. For organizations just starting their accessibility journey, WCAG-EM 2.0 offers a comprehensive framework that covers their entire digital presence from day one, ensuring disabled users get consistent access across all platforms.
The draft status means we're likely 6–12 months away from a final recommendation. But smart teams will start experimenting with the methodology now, especially if they're planning accessibility audits or accessibility improvements in 2026.
This isn't just another W3C document—it's a practical tool that could finally bring consistency to accessibility evaluation across the entire digital ecosystem. For development teams committed to serving disabled users but struggling with different testing approaches for different platforms, WCAG-EM 2.0 might be exactly what they've been waiting for.
About Marcus
Seattle-area accessibility consultant specializing in digital accessibility and web development. Former software engineer turned advocate for inclusive tech.
Specialization: Digital accessibility, WCAG, web development
View all articles by Marcus →Transparency Disclosure
This article was created using AI-assisted analysis with human editorial oversight. We believe in radical transparency about our use of artificial intelligence.