- Primary legal source for Article 14, Annex VI criteria, Article 16 declaration wording, authority review, and Annex IV technical documentation.
"Fundamental alteration and disproportionate burden"
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.
Structured answer sets in this page tree.
Cited legal and guidance references.
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.
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.
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.
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.
"Fundamental alteration and disproportionate burden"
"Fundamental alteration and disproportionate burden"
"which accessibility requirements are subject to that exception"
"renew their assessment"
"A harmonised standard is a European standard"