--- title: "EU Accessibility Act Requirements: Annex I, Products, Services" canonical_url: "https://www.sorena.io/artifacts/eu/accessibility-act/requirements" source_url: "https://www.sorena.io/artifacts/eu/accessibility-act/requirements" author: "Sorena AI" description: "Map EU Accessibility Act requirements by Article 4, Annex I, product and service obligations, Article 13 evidence, standards, and Article 14 exceptions." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Accessibility Act requirements" - "EAA Annex I" - "Directive (EU) 2019/882 Article 4" - "EAA Article 13" - "EAA Article 14" - "EU Accessibility Act" - "EAA" - "Directive (EU) 2019/882" - "Annex I" - "Article 4" - "Article 13" - "Article 14" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Accessibility Act Requirements: Annex I, Products, Services Map EU Accessibility Act requirements by Article 4, Annex I, product and service obligations, Article 13 evidence, standards, and Article 14 exceptions. *Requirements Guide* *EU* ## EU Accessibility Act Requirements Directive (EU) 2019/882 requires covered products and services to meet the accessibility requirements in Annex I, subject to the Article 14 limits for fundamental alteration and disproportionate burden. This page helps separate product duties from service duties, identify the Annex I section to test, and keep evidence that matches Articles 4, 13, 14, 15, and the conformity annexes. The EU Accessibility Act sets common accessibility requirements for certain products and services across the EU. This page explains which products and services are covered, which Annex I requirements apply, what evidence service providers and product manufacturers should keep, and when Article 14 may limit compliance because of fundamental alteration or disproportionate burden. ## Article 4 turns Annex I into the requirements checklist 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. - Covered products include consumer general purpose computer hardware and operating systems, specified self-service terminals, consumer terminal equipment used for electronic communications or audiovisual media access, and e-readers. - Covered services include electronic communications services, access to audiovisual media services, specified passenger transport service elements, consumer banking services, e-books and dedicated software, and e-commerce services. - Microenterprises providing services are exempt from the Article 4 service accessibility requirements and related obligations; microenterprises dealing with products are treated differently and may still need product-side assessment. Sources for this answer: - [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/eli/dir/2019/882/oj?ref=sorena.io) - Supports the Article 2 scope categories and Article 4 rule that covered products and services must meet the applicable Annex I requirements, subject to Article 14. *Recommended next step* *Placement: after requirements sections* ## Turn EAA requirements into product and service evidence Build an EAA evidence pack that separates Article 4 scope, Annex I product and service tests, Article 13 public service information, standards coverage, and any Article 14 assessment. - [Open Research Copilot](/solutions/research-copilot.md): Check EAA scope, Annex I mapping, and standards evidence with cited outputs. - [Talk through implementation](/contact.md): Review your product, service, standards, and Article 14 evidence model. ## Product requirements: design, information, interfaces, packaging, and conformity evidence 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. - Manufacturers must design and manufacture covered products in accordance with applicable EAA accessibility requirements, draw up Annex IV technical documentation, complete the conformity assessment, draw up the EU declaration of conformity, and affix CE marking when conformity is demonstrated. - Importers must check that the manufacturer has carried out the Annex IV conformity assessment, prepared technical documentation, applied CE marking, and supplied required documents before placing a product on the market. - Distributors must act with due care, verify CE marking and required documents, and avoid making products available when they have reason to believe the product is not conforming. Sources for this answer: - [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/eli/dir/2019/882/oj?ref=sorena.io) - Supports the product-side Annex I requirements and Articles 7 to 10 obligations for manufacturers, importers, and distributors. ## Service requirements: Article 13 information and Annex V evidence 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. - Put the Article 13 explanation in the general terms and conditions or an equivalent public document, as Annex V requires. - Describe the service, how it operates, and how the relevant Annex I requirements are met by the design and operation of the service. - Keep monitoring evidence for service changes, changed accessibility requirements, and changes in harmonised standards or technical specifications used as the conformity basis. Sources for this answer: - [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/eli/dir/2019/882/oj?ref=sorena.io) - Supports Article 13 service-provider duties and Annex V public information requirements for services meeting accessibility requirements. ## Standards can support evidence, but they do not replace the law 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. - Record whether each cited standard is an OJEU-cited harmonised standard for the relevant EAA requirement or only a useful technical benchmark. - When applying a standard only in part, record the exact clauses used and map remaining Annex I requirements to test results, technical specifications, or other verifiable documentation. - Do not describe EN 301 549 V3.2.1 as automatically proving EAA compliance unless the cited legal effect and covered requirements are verified. Sources for this answer: - [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/eli/dir/2019/882/oj?ref=sorena.io) - Supports the Article 15 presumption-of-conformity rule and its limit to standards or parts of standards that cover the relevant requirements. - [European Commission - Harmonised standards](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en?ref=sorena.io) - Supports the boundary that harmonised standards are voluntary tools for demonstrating compliance and require OJEU publication for legal effect. - [ETSI - EN 301 549 V3 ICT accessibility standard overview](https://www.etsi.org/human-factors-accessibility/en-301-549-v3-the-harmonized-european-standard-for-ict-accessibility?ref=sorena.io) - Supports using EN 301 549 as ICT accessibility evidence while noting that the V3.2.1 overview identifies Web Accessibility Directive support and a planned EAA-supporting revision. ## Article 14 exceptions require a documented assessment 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. - Use Annex VI for disproportionate-burden analysis: net compliance costs against overall costs, estimated costs and benefits including benefits for persons with disabilities, and net costs against net turnover. - Do not rely on disproportionate burden where accessibility funding from public or private sources was provided for the relevant accessibility improvement. - If Article 14 is used for a product, the EU declaration of conformity must state which accessibility requirements are subject to that exception. Sources for this answer: - [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/eli/dir/2019/882/oj?ref=sorena.io) - Supports the Article 14 fundamental-alteration and disproportionate-burden limits, evidence retention rule, renewal triggers, and Annex VI criteria. ## Primary sources - [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/eli/dir/2019/882/oj?ref=sorena.io) - Primary legal source for EAA scope, Article 4 requirements, product obligations, Article 13 service-provider obligations, Article 14 exceptions, Article 15 presumption of conformity, and Annex I, IV, V, and VI evidence. - Quote: "accessibility requirements for products and services" - [European Commission - European Accessibility Act policy page](https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/union-equality-strategy-rights-persons-disabilities-2021-2030/european-accessibility-act_en?ref=sorena.io) - Official Commission EAA overview source for public context on Directive (EU) 2019/882 and its accessibility policy purpose. - Quote: "European Accessibility Act" - [European Commission - Harmonised standards](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en?ref=sorena.io) - Explains that harmonised standards are voluntary compliance tools and that OJEU publication is the publication step tied to presumption of conformity or other legal effect. - Quote: "The use of these standards remains voluntary." - [ETSI - EN 301 549 V3 ICT accessibility standard overview](https://www.etsi.org/human-factors-accessibility/en-301-549-v3-the-harmonized-european-standard-for-ict-accessibility?ref=sorena.io) - Identifies EN 301 549 as an ICT accessibility standard and grounds the caution that V3.2.1 supports the Web Accessibility Directive while an EAA-supporting revision is planned. - Quote: "Accessibility requirements for ICT products and services" ## Related Topic Guides - [EAA Accessibility Conformance Statement Template](/artifacts/eu/accessibility-act/accessibility-conformance-statement-template.md): Template language for an EU Accessibility Act conformance statement covering scope, Annex I mapping, service information, standards, support routes, evidence, and limits. - [EAA Article 14 disproportionate burden workflow](/artifacts/eu/accessibility-act/disproportionate-burden-assessment-workflow.md): A cited EU Accessibility Act workflow for Article 14 fundamental alteration and disproportionate burden assessments, records, reassessment triggers, and evidence. - [EAA conformance statements: products, services, EN 301 549 evidence](/artifacts/eu/accessibility-act/faq/conformance-statements.md): What an EU Accessibility Act conformance statement should include, with product EU declarations, service information, EN 301 549 and WCAG evidence boundaries. - [EAA e-commerce checkout accessibility FAQ](/artifacts/eu/accessibility-act/faq/e-commerce-checkout.md): How to test an e-commerce checkout under the European Accessibility Act, including service scope, payment and identification flows, service information, and evidence. - [EAA e-commerce checkout accessibility guide](/artifacts/eu/accessibility-act/e-commerce-checkout-accessibility.md): Official source EU Accessibility Act guide for accessible e-commerce checkout scope, payment and identification requirements, evidence, standards mapping, and customer information. - [EAA EN 301 549 and WCAG mapping](/artifacts/eu/accessibility-act/en-301-549-and-wcag-mapping.md): Map European Accessibility Act Annex I requirements to EN 301 549 and WCAG evidence without overstating what WCAG tests can prove. - [EAA EN 301 549 clause mapping for ICT evidence](/artifacts/eu/accessibility-act/en-301-549-clause-mapping.md): Map EN 301 549 clauses to EU Accessibility Act evidence, Annex I outcomes, product and service records, and gaps that need non-ICT support. - [EAA procurement clauses and accessibility acceptance criteria](/artifacts/eu/accessibility-act/procurement-language-and-acceptance-criteria.md): Buyer-side EU Accessibility Act procurement language for covered products and services, with supplier evidence, EN 301 549 limits, Article 14 exception records, and acceptance criteria. - [EAA scope classifier workflow for products and services](/artifacts/eu/accessibility-act/accessibility-scope-classifier-workflow.md): Classify EU Accessibility Act scope by product or service category, consumer use, market or service date, operator role, exclusions, exemptions, Article 14 records, and evidence. - [EAA testing and conformance evidence | Annex I, EN 301 549 and Article 14](/artifacts/eu/accessibility-act/testing-and-conformance-evidence.md): How to document European Accessibility Act testing evidence: Annex I mappings, product technical files, service information, EN 301 549 boundaries, harmonised-standard limits, and Article 14 exception records. - [EAA WCAG evidence and procurement acceptance](/artifacts/eu/accessibility-act/wcag-evidence-and-procurement-acceptance.md): How to use EN 301 549 and WCAG evidence in EU Accessibility Act procurement acceptance without overstating presumption of conformity. - [EN 301 549 clause mapping for the EU Accessibility Act | EAA FAQ](/artifacts/eu/accessibility-act/faq/en-301-549-clause-mapping.md): How to map EN 301 549 and WCAG evidence to EU Accessibility Act Annex I requirements without overclaiming presumption of conformity. - [EN 301 549 evidence matrix workflow for EAA readiness](/artifacts/eu/accessibility-act/en-301-549-evidence-matrix-workflow.md): Build an EN 301 549 evidence matrix for European Accessibility Act work: scope rows, clause mapping, test evidence, owner sign-off, exception records, and limits of standards evidence. - [EN 301 549 vs WCAG for EAA evidence](/artifacts/eu/accessibility-act/en-301-549-vs-wcag.md): Compare EN 301 549 and WCAG for European Accessibility Act planning: ICT scope, web-content overlap, harmonised-standard limits, and evidence beyond WCAG-only tests. - [EU Accessibility Act Applicability Test](/artifacts/eu/accessibility-act/applicability-test.md): Check whether the European Accessibility Act covers a product or consumer service, which role applies, which date matters, and what evidence to keep. - [EU Accessibility Act authority request response FAQ](/artifacts/eu/accessibility-act/faq/authority-response.md): How to answer EU Accessibility Act checks from market surveillance or service authorities with technical documentation, service information, Article 14 records, and corrective actions. - [EU Accessibility Act checklist for products and services](/artifacts/eu/accessibility-act/checklist.md): Checklist for EAA scope, operator role, Annex I mapping, product technical files, service information, Article 14 assessments, supplier evidence, release checks, and monitoring. - [EU Accessibility Act compliance operating model](/artifacts/eu/accessibility-act/compliance.md): Build an EU Accessibility Act compliance file for covered products and services: scope, operator roles, Annex I mapping, conformity evidence, Article 14 assessments, corrective actions, and records. - [EU Accessibility Act deadlines and compliance calendar](/artifacts/eu/accessibility-act/deadlines-and-compliance-calendar.md): Calendar for the EU Accessibility Act: 2022 transposition, 2025 application, 2027 emergency communications timing, 2030 transition rules, owner actions, and evidence records. - [EU Accessibility Act deadlines and transition plan](/artifacts/eu/accessibility-act/deadlines-and-transition-plan.md): Plan for the European Accessibility Act application date, service-contract transition, self-service terminal transition, 112 derogation, and evidence gates. - [EU Accessibility Act disproportionate burden decision](/artifacts/eu/accessibility-act/disproportionate-burden-decision.md): How to document an EU Accessibility Act Article 14 disproportionate burden decision with supported criteria, retained evidence, limits, notifications, and review triggers. - [EU Accessibility Act exemptions and disproportionate burden](/artifacts/eu/accessibility-act/exemptions-and-disproportionate-burden.md): Article 14 EAA guide covering fundamental alteration, disproportionate burden, service microenterprise exemptions, content exclusions, transition limits, and documentation. - [EU Accessibility Act FAQ: scope, dates, services, Article 14](/artifacts/eu/accessibility-act/faq.md): Clear answers on EU Accessibility Act scope, 28 June 2025 application, covered products and services, microenterprises, Article 14, service information, standards, and penalties. - [EU Accessibility Act for ecommerce websites](/artifacts/eu/accessibility-act/accessibility-act-for-ecommerce-websites.md): Official source guide for ecommerce teams applying the EU Accessibility Act to consumer checkout journeys, service information, accessibility evidence, and exceptions. - [EU Accessibility Act microenterprise exemption and disproportionate burden FAQ](/artifacts/eu/accessibility-act/faq/microenterprise-and-disproportionate-burden-decisions.md): FAQ explaining when EAA microenterprise relief applies, how Article 14 disproportionate-burden assessments work, what Annex VI requires, and what records to keep. - [EU Accessibility Act penalties and enforcement](/artifacts/eu/accessibility-act/penalties-and-fines.md): How Directive (EU) 2019/882 handles penalties, Member State enforcement, market surveillance for products, and service compliance checks. - [EU Accessibility Act procurement acceptance criteria | EAA FAQ](/artifacts/eu/accessibility-act/faq/procurement-acceptance.md): How to write EAA procurement acceptance criteria that ask suppliers for scoped accessibility evidence, standards mappings, declarations, and exception records without overclaiming conformity. - [EU Accessibility Act Product and Service Scope](/artifacts/eu/accessibility-act/product-and-service-category-scoping.md): Scope products and services under the EU Accessibility Act using Article 2 categories, Article 3 definitions, limited content exclusions, microenterprise treatment, and evidence records. - [EU Accessibility Act products and services in scope](/artifacts/eu/accessibility-act/products-and-services-in-scope.md): Article 2 scope guide for the European Accessibility Act: covered products, covered consumer services, economic-operator roles, Article 3 definitions, and evidence records. - [EU Accessibility Act service transition rules under Article 32 | EAA FAQ](/artifacts/eu/accessibility-act/faq/transition-services.md): FAQ on EU Accessibility Act Article 32 transition rules for service providers, pre-28 June 2025 contracts, 2030 limits, self-service terminals, evidence records, and change triggers. - [EU Accessibility Act services: banking, transport, media and e-books](/artifacts/eu/accessibility-act/faq/banking-transport-and-media-services.md): FAQ on which consumer banking, transport, audiovisual media access, electronic communications, e-book, and e-commerce services fall under the EU Accessibility Act. - [EU Accessibility Act vs ADA and Section 508: EAA-cited-source comparison](/artifacts/eu/accessibility-act/accessibility-act-vs-ada-and-section-508.md): Compare the EU Accessibility Act with ADA and Section 508 planning boundaries, using official source EAA scope, evidence, standards, procurement, and operator-duty points. - [EU Accessibility Act vs Web Accessibility Directive](/artifacts/eu/accessibility-act/accessibility-act-vs-web-accessibility-directive.md): Compare the European Accessibility Act with the Web Accessibility Directive: scope, covered actors, services, standards, evidence, monitoring, enforcement, and key dates. - [WCAG Evidence for the EU Accessibility Act and EN 301 549 | EAA FAQ](/artifacts/eu/accessibility-act/faq/wcag-evidence.md): When WCAG test evidence helps EAA work, how it maps through EN 301 549, and why WCAG alone does not prove European Accessibility Act compliance. - [Which products and services does the EU Accessibility Act cover? | EAA FAQ](/artifacts/eu/accessibility-act/faq/product-and-service-categories.md): Article 2 and Article 3 scope summary for EU Accessibility Act covered products, services, exclusions, product-service boundaries, and records to keep. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). All rights reserved. Source: https://www.sorena.io/artifacts/eu/accessibility-act/requirements