Artifact GuideEU

EU Accessibility Act Requirements

A grounded view of the EU Accessibility Act requirements that matter in delivery: Annex I outcomes, role based duties, and the evidence needed to prove work was done.

The requirement set is broader than web accessibility alone. It covers product information, interfaces, support, and service delivery conditions.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 23, 2026
Sections
2

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 23, 2026
Overview

The directive is outcome based, but teams still need an implementation structure. The right approach is to separate three layers: first, the Annex I accessibility outcomes that apply to the offering; second, the duties that attach to the business role for that offering; third, the evidence needed to prove the requirement was addressed. That is what this page is designed to help you do.

Section 1

Annex I requirements in practical terms

Annex I requires that information, user interfaces, and supporting features be accessible so disabled users can perceive, operate, understand, and benefit from the offering. For products, that can reach the product itself, packaging information, instructions, and interfaces. For services, it reaches the information about the service and the digital channels through which the service is delivered.

The local grounding pack also shows that specific categories receive more detailed functional requirements. For example, e-readers are expected to provide text to speech technology, communications services require alternatives to voice only interaction and synchronised emergency communications features where applicable, and media access services must preserve accessibility components such as subtitles and audio description.

  • Identify which Annex I sections apply to the exact category in scope.
  • Cover information, instructions, labels, controls, and support features, not only the main UI.
  • Translate each requirement into a measurable behaviour or acceptance criterion.
  • Use plain language, clear instructions, and accessible interaction patterns across all user facing materials.
Recommended next step

Turn EU Accessibility Act Requirements into an operational assessment

Assessment Autopilot can take EU Accessibility Act Requirements from turning the requirements into assigned actions to a reusable workflow inside Sorena. Teams working on EU Accessibility Act can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Section 2

Role duties and evidence expectations

Product roles create specific legal duties. Manufacturers need technical documentation under Annex IV, conformity assessment, and an EU declaration of conformity, which then supports the product being placed on the market. Importers must verify the manufacturer has done that work and keep a copy of the declaration for five years while ensuring the technical documentation can be made available. Distributors must not make products available when they know or have reason to believe they are not compliant.

Services do not follow the same declaration workflow, but they still need a disciplined evidence pack. That pack should show scope, requirements, standards used, tests run, barriers identified, remediations completed, any exceptions relied on, and the owner responsible for keeping the record current.

  • For products, prepare Annex IV documentation and declaration processes before launch.
  • For services, maintain a traceable evidence pack by channel and release.
  • Keep five year retention rules in mind for product documentation and Article 14 records.
  • Make sure procurement statements, sales claims, and support scripts all reflect the same requirement position.
Primary sources

References and citations

etsi.org
Referenced sections
  • Official ETSI overview of EN 301 549, the European accessibility standard used to operationalise ICT requirements across web, software, hardware, documents, and communications.
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