WorkflowEU Accessibility Act

Article 14 disproportionate burden assessment workflow

Under Directive (EU) 2019/882, an accessibility requirement applies only to the extent that compliance would not fundamentally alter the product or service's basic nature or impose a disproportionate burden on the economic operator.

This workflow helps document the Article 14 assessment, keep the required evidence, trigger reassessment for services, and show authorities which accessibility requirements are affected.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

This workflow is for EU Accessibility Act exceptions. It is not a general accessibility backlog tool: it should be used only when a covered product or service cannot fully meet one or more applicable accessibility requirements because the change would fundamentally alter its basic nature or because the Annex VI burden assessment supports a disproportionate-burden conclusion.

Section 1

Start with the Article 14 boundary

Open an assessment only after the product or service, economic-operator role, applicable Article 4 accessibility requirement, and affected feature have been identified. The assessment should be written requirement by requirement, because Article 14 does not remove the duty to meet accessibility requirements that are not affected by the exception.

Separate the two grounds. A fundamental alteration record explains why the required change would significantly change the basic nature of the product or service. A disproportionate burden record applies the Annex VI cost and benefit criteria. The Directive supplies ratios and cost inputs, but no automatic percentage or monetary threshold; the conclusion must follow from the documented facts.

  • Record the specific product or service category, Member State market, economic operator, and accessibility requirement being assessed.
  • State whether the exception is fundamental alteration, disproportionate burden, or both; do not use one label to cover the other.
  • For disproportionate burden, show the Annex VI ratios and inputs used: net compliance costs against overall operating and capital costs, estimated costs and benefits against benefit for persons with disabilities, and net compliance costs against net turnover.
  • Continue applying every accessibility requirement that is not covered by the documented exception.
Section 2

Build the assessment record

The record should be complete enough for a market surveillance authority or a service-compliance authority to review without reconstructing the analysis from emails. Keep the accessibility requirement, evidence, cost inputs, decision, and reviewer approval in one version-controlled file or evidence pack.

For products, connect the record to the technical documentation and, where Article 14 is used, the EU declaration of conformity must identify which accessibility requirements are subject to the exception. For services, connect the record to the service description, customer-facing accessibility information, test evidence, and the reassessment log.

  • Assessment header: product or service name, version, market, operator role, owner, date of assessment, and ground used.
  • Requirement table: applicable accessibility requirement, implementation option considered, affected feature, evidence reviewed, and whether the requirement is fully met, partly met, or subject to .
  • Fundamental alteration evidence: the product or service function at issue, the change required for accessibility, and why that change would significantly alter the basic nature of the offering.
  • Disproportionate burden evidence: one-off organisational costs, ongoing design, manufacturing, testing, and documentation costs, expected benefits for persons with disabilities, expected frequency of use, turnover context, and funding status.
  • Decision fields: conclusion for each affected requirement, remaining accessibility measures still implemented, (8) information sent to the relevant authorities unless the operator is a microenterprise, next reassessment trigger, approver, and evidence location.
Recommended next step

Review an Article 14 evidence file before relying on it

Use the workflow to check whether the exception is tied to a specific accessibility requirement, supported by Annex VI evidence, reflected in product or service records, and scheduled for reassessment where Article 14 requires it.

Section 3

Retention, reassessment, and authority review

records are not one-off release notes. Economic operators must document the assessment and keep relevant results for five years from the last making available of a product on the market or after a service was last provided, as applicable.

Service providers relying on disproportionate burden must renew the assessment for each category or type of service when the service is altered, when the responsible authority requests it, and at least every five years. Economic operators that receive public or private funding, other than their own resources, for improving accessibility cannot rely on disproportionate burden. That funding rule does not remove the separate fundamental-alteration ground.

The Directive gives microenterprises two narrow procedural carve-outs. A microenterprise dealing with products need not document the assessment, but must give the market surveillance authority the relevant facts if requested. Microenterprises do not have to send the Article 14(8) reliance notice. These carve-outs do not create a general Article 14 exemption; the operator must still have facts supporting the ground it relies on.

  • Keep the signed assessment, requirement table, cost model, evidence references, authority notifications, and reassessment history for the retention period.
  • Trigger reassessment when a service changes, when the authority responsible for checking services requests it, or when the five-year service reassessment interval is reached.
  • For products, be ready for market surveillance authorities to check whether the assessment was conducted and to review the assessment, results, and use of Annex VI criteria.
  • For services, be ready for authorities to check compliance procedures that include the assessment.
  • If the file relies on disproportionate burden, add a funding check that confirms whether public or private accessibility-improvement funding was received.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Article 14 sets the two grounds, Annex VI supplies the disproportionate-burden criteria without a fixed threshold, and recital 66 says lack of priority, time, or knowledge is not a legitimate reason for a burden claim.
"Fundamental alteration and disproportionate burden"
eur-lex.europa.eu
Referenced sections
  • Article 14 requires the assessment, documentation, and five-year retention; Article 16 requires a product's EU declaration of conformity to identify requirements subject to an Article 14 exception; Annex IV describes the supporting technical documentation.
"which accessibility requirements are subject to that exception"
eur-lex.europa.eu
Referenced sections
  • Article 14 sets retention, reassessment, funding, and authority-information rules; Articles 19 and 23 cover authority checks for products and services.
"renew their assessment"
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