EU Accessibility Act Requirements

Article 4 is the legal switchboard for requirements. It points products to Annex I Section I, adds Annex I Section II for products other than self-service terminals, points most services to Annex I Section III, and applies Annex I Section IV to services for the sector-specific additions.

That means the first implementation step is not a generic accessibility audit. It is a scope match: identify the covered product or service, identify the operator role, then test only the Annex I sections that Article 4 makes applicable to that category.

For products, Annex I Section I covers information on use and accessibility features, user interface and functionality design, and available support services. Product teams should map each relevant feature to the Section I outcomes: multiple sensory channels, alternatives to speech, colour, audio, biometrics and fine motor control, sufficient interaction time, privacy for accessibility features, and assistive-technology interoperability.

Annex I Section II adds packaging and instruction requirements for covered products other than self-service terminals. Product evidence therefore needs more than a test score: it should connect the physical product, embedded software, instructions, packaging, support material, tested assistive devices, and any applied standards or technical specifications.

For services, Annex I Section III requires accessible service information, accessible websites and mobile services, accessible electronic information needed in service provision, and accessible support information where support services are available. Annex I Section IV then adds rules for specific service categories, including real-time text and total conversation for electronic communications, accessible electronic programme guides, transport information, consumer banking identification and payment flows, e-book accessibility, and e-commerce identification, security and payment functionality.

Article 13 makes this operational for service providers. They must design and provide services in accordance with the EAA, prepare information explaining how the service meets the applicable requirements, make that information public in written and oral format in an accessible manner, keep it while the service operates, maintain conformity procedures, correct non-conformity, notify competent national authorities when a service is not compliant, and cooperate with authority requests.

Article 15 creates a presumption of conformity only for products and services that conform with harmonised standards, or parts of standards, whose references have been published in the Official Journal of the European Union, and only so far as those standards or parts cover the relevant EAA requirements.

The Commission harmonised-standards guidance also makes the boundary clear: use of harmonised standards remains voluntary, and economic operators may choose another technical solution to demonstrate compliance with mandatory legal requirements. EN 301 549 is useful for ICT accessibility evidence, but the ETSI overview states that the current EN 301 549 V3.2.1 supports the Web Accessibility Directive and is planned to be updated to support Directive (EU) 2019/882.

Article 14 is not a blanket exemption from EAA requirements. It limits the Article 4 accessibility requirements only to the extent that compliance would require a significant change causing fundamental alteration of the product or service's basic nature, or would impose a disproportionate burden on the economic operator.

Economic operators relying on Article 14 must assess the issue, document the assessment, keep relevant results for five years from the last making available of the product or after the service was last provided, and provide a copy to the relevant authority on request. Service providers relying on disproportionate burden must renew the assessment when the service changes, when requested by the authority, and at least every five years.