WorkflowEU Accessibility Act

Article 14 disproportionate burden assessment workflow

Directive (EU) 2019/882 allows accessibility requirements to be limited only where compliance would fundamentally alter the product or service, or impose a disproportionate burden on the economic operator.

Use this workflow to document the Article 14 assessment, keep the required evidence, trigger reassessment for services, and show authorities exactly which accessibility requirements are affected.

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Author

Sorena AI

Published

May 9, 2026

Updated

May 9, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

This workflow is for EU Accessibility Act Article 14 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 Article 14 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 Article 14 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 explains why compliance would impose an excessive burden after applying the relevant criteria, including Annex VI cost and benefit factors.

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.

Sources for this answer

Directive (EU) 2019/882, Article 14 and Annex VI

Article 14 sets the fundamental-alteration and disproportionate-burden grounds; Annex VI supplies the criteria for assessing disproportionate burden.

Directive (EU) 2019/882, recital 66

Recital 66 explains that lack of priority, time, or knowledge is not a legitimate reason for claiming disproportionate burden.

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 Article 14 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 Article 14 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 Article 14.
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: final conclusion, remaining accessibility measures still implemented, authority-notification status where required, next reassessment trigger, approver, and evidence location.

Sources for this answer

Directive (EU) 2019/882, Article 16 and Annex IV

Article 16 requires the EU declaration of conformity to identify accessibility requirements subject to an Article 14 exception; Annex IV describes technical documentation when Article 14 is relied on.

Directive (EU) 2019/882, Article 14(3)

Article 14(3) requires economic operators to document the assessment and keep relevant results for five years.

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.

Research workflow

Open Research Copilot

Check EAA Article 14 questions against cited EU sources.

Explore next step

Talk to Sorena

Talk through implementation

Review your Article 14 record structure, evidence gaps, and reassessment triggers.

Explore next step

Section 3

Retention, reassessment, and authority review

Article 14 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. If accessibility funding from public or private sources was provided for improving accessibility, Article 14 does not allow reliance on disproportionate burden for that funded issue.

Keep the signed assessment, requirement table, cost model, evidence references, authority notifications, and reassessment history for the Article 14 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 Article 14 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 Article 14 assessment.
If the file relies on disproportionate burden, add a funding check that confirms whether public or private accessibility-improvement funding was received for the same issue.

Sources for this answer

Directive (EU) 2019/882, Articles 14, 19, and 23

Article 14 sets retention, reassessment, funding, and authority-information rules; Articles 19 and 23 cover authority checks for products and services.

European Commission harmonised standards overview

Commission guidance explains the role of harmonised standards and OJEU publication when documenting technical routes to conformity.

Primary sources

References and citations

Directive (EU) 2019/882 on accessibility requirements for products and services

eur-lex.europa.eu

Referenced sections

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"

Directive (EU) 2019/882, Article 14 and Annex VI

eur-lex.europa.eu

Referenced sections

Article 14 sets the fundamental-alteration and disproportionate-burden grounds; Annex VI supplies the criteria for assessing disproportionate burden.

"Fundamental alteration and disproportionate burden"

Directive (EU) 2019/882, Article 14(3)

eur-lex.europa.eu

Referenced sections

Article 14(3) requires economic operators to document the assessment and keep relevant results for five years.

"keep all relevant results for a period of five years"

Directive (EU) 2019/882, Article 16 and Annex IV

eur-lex.europa.eu

Referenced sections

Article 16 requires the EU declaration of conformity to identify accessibility requirements subject to an Article 14 exception; Annex IV describes technical documentation when Article 14 is relied on.

"which accessibility requirements are subject to that exception"

Directive (EU) 2019/882, Articles 14, 19, and 23

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.