Mobile Development in der DACH-Region: Compliance, Datenschutz und technische Anforderungen für 2025

Introduction: Why DACH Mobile App Compliance Matters in 2025

Mobile app development in the DACH region (Germany, Austria, and Switzerland) faces the most stringent regulatory environment globally. With the European Accessibility Act (EAA) becoming binding throughout the EU on 28 June 2025, and the EU Data Act becoming applicable on September 12, 2025, mobile development teams must navigate increasingly complex compliance obligations that set European—and particularly German-speaking—markets distinctly apart from global standards.

At IntegrIT Solutions (https://www.integritsol.de), we specialize in helping businesses build mobile applications that not only meet these stringent requirements but leverage them as competitive advantages in the German, Austrian, and Swiss markets. This comprehensive guide addresses the critical compliance, privacy, and technical considerations that define successful mobile app development in the DACH region in late 2025.

2. The European Accessibility Act: A New Era for Mobile App Development

What Changed on June 28, 2025

The European Accessibility Act is due to become law in Europe, and it defines specific requirements for mobile—it's the first accessibility legislation anywhere that explicitly covers mobile apps.

With its official adoption in 2019, the EAA became binding throughout the EU on 28 June 2025, fundamentally changing mobile app development requirements across Germany, Austria, and Switzerland.

Which Mobile Apps Must Comply with the EAA?

The EAA applies broadly across sectors affecting most commercial mobile applications:

1. Transport Services: Any app related to publicly available transport including air, bus, rail and waterborne transport

1. Banking and Financial Services: Websites and mobile apps offering banking and financial services, including online banking, loan services, and investment platforms

1. E-Commerce: Any app that allows for digitally purchasing either digital or physical goods or services—this clause will cover the majority of apps, and the requirements here are not as detailed as the more specific domains above

EAA Implications for the DACH Region

The EAA may seem like a general EU regulation, but it has significant implications for companies in the DACH region, and for companies operating in the digital space through websites, apps or other digital services, the EAA represents a binding framework that cannot be ignored.

4. The EU Data Act: New Data Sharing Requirements for Mobile Apps

What is the EU Data Act?

The EU Data Act became applicable on September 12, 2025, establishing requirements for applications that generate or process data from connected devices and digital services, with app developers serving users in the European Union required to implement these requirements.

Key Requirements for Mobile Developers in the DACH Region

The regulation grants users rights to access data generated through applications, establishes requirements for business-to-business data sharing, and mandates cloud service interoperability and data portability, with applications required to provide users with mechanisms to access their data, authorize third-party data sharing, and export data in standardized formats—these requirements apply to all applications serving EU users regardless of the developer's location.

• Build data export functionality (JSON, CSV formats)
• Create user data dashboards showing all collected data
• Implement third-party data sharing authorization flows
• Provide standardized data portability mechanisms

Data Act + EAA Intersection

The European Accessibility Act requires that data access mechanisms be designed to be usable by all individuals, including those with disabilities, meaning tools that allow users to see, download, or share their data must be easy for everyone to use.

6. Platform-Specific Considerations: iOS and Android in the DACH Market

iOS Privacy Requirements in 2025

ATT Framework has matured since its 2021 introduction, with 2025 updates requiring specific third-party data recipient disclosure—generic "tracking for ads" notifications must now specify actual partners.

Common misconceptions persist about ATT scope—the framework doesn't replace GDPR requirements or eliminate the need for additional controls within apps.

• ATT prompt must use clear, non-technical language
• Specify actual data recipients ("Share with Meta for advertising")
• Implement separate GDPR consent mechanisms
• Provide easy opt-out mechanisms

Android Permission Management

Android permission integration works with the platform security model while providing comprehensive privacy controls for all personal data processing, and platform-specific features utilization optimizes privacy controls for each platform's capabilities while maintaining consistent user experience across devices.

• Request permissions in context when needed
• Explain why each permission is necessary
• Provide graceful degradation when permissions denied
• Implement separate GDPR consent flows

8. Competitive Advantages of DACH-Compliant Mobile App Development

Market Access and Trust

Compliance with GDPR isn't merely a legal obligation; it's a strategic advantage, as adhering to GDPR requirements helps mobile apps avoid significant financial penalties and build a reputation for protecting user privacy.

Broader User Base Through Accessibility

By making your digital products accessible, you open up your business to a larger audience, including millions of people with disabilities.

• 15-20% of the EU population has some form of disability
• Accessible design benefits all users (elderly, temporary disabilities, situational limitations)
• Better usability leads to higher conversion rates

Trust Building in Privacy-Conscious Markets

Compliance goes beyond avoiding penalties—it shows respect for user privacy, inclusivity, and security, building user trust and loyalty and turning regulatory burden into competitive edge.

Germany, Austria, and Switzerland are among the world's most privacy-conscious markets. Demonstrating robust compliance:

• Differentiates your app from international competitors
• Builds brand reputation
• Increases user retention
• Enables premium positioning

Future-Proofing Your Mobile App

Regulations will only get stricter. Building compliance into your development process now prevents costly retrofitting later and positions your app for success as enforcement increases across the DACH region.

10. Looking Ahead: 2026 and Beyond for DACH Mobile Apps

Regulatory Evolution

The European Council and the European Parliament reached agreement in June 2025 on reform efforts, with updates primarily focused on clarifying the original GDPR text rather than making substantive changes.

Increased Enforcement

Expect heightened enforcement across Germany, Austria, and Switzerland in 2026:

• More accessibility audits and complaints
• Stricter GDPR penalties
• Greater scrutiny of international data transfers
• Consumer association warnings for non-compliance

Emerging Technologies

As AI and machine learning features become standard in mobile apps, additional compliance considerations will emerge:

• AI Act requirements (coming 2026-2027)
• Algorithmic transparency obligations
• Enhanced data minimization requirements

Key Takeaways for DACH Mobile App Developers

• GDPR: Technical permissions ≠ consent; implement separate, explicit consent mechanisms
• EAA/BFSG: Accessibility mandatory from June 28, 2025 for e-commerce and service apps
• Data Residency: Store EU data in EU regions; document all transfers outside EEA
• EU Data Act: Provide data portability and user data access mechanisms
• Platform Requirements: iOS ATT and Android permissions don't replace GDPR
• Documentation: Maintain comprehensive records of processing, accessibility, and compliance
• Competitive Edge: Use compliance to differentiate in privacy-conscious DACH markets