Annex I: Accessibility Requirements

Annex I of the European Accessibility Act sets out detailed accessibility requirements for products and services covered by the directive. These requirements aim to ensure that persons with disabilities can access and use products and services on an equal basis with others.

The requirements are organized into sections for different types of products and services, with both general requirements applicable to all products and services and specific requirements for particular sectors.

These requirements apply to all products covered by the EAA, including consumer electronic devices, self-service terminals, e-readers, and more:

1. Information Provision: Products must provide information on their use (instructions, packaging, etc.) in accessible formats that:
   • Are perceivable through more than one sensory channel
   • Are presented in an understandable way
   • Are presented to users in ways they can perceive
   • Use adequate size, shape, contrast, spacing, etc. of text
   • Complement text with non-text formats when needed
2. User Interface and Functionality: The product interface, including operation, controls, and feedback, must be made accessible by:
   • Providing communication through more than one sensory channel
   • Providing alternatives to speech for communication and operation
   • Allowing flexible magnification, contrast, and brightness
   • Providing alternative color controls
   • Avoiding triggering seizures and allowing adequate time for interactions
   • Providing alternatives to fine motor control and simultaneous actions
   • Avoiding operation modes requiring extensive reach and strength
   • Accounting for light sensitivity and minimizing triggering of allergic reactions
3. Support Services: Support services (helpdesks, call centers, etc.) must provide information about the product's accessibility in accessible modes of communication.

Product Packaging and Instructions

Packaging and instructions must be accessible to persons with disabilities and should:

• Make packaging information (product identification, opening instructions, etc.) accessible
• Provide instructions for installation, maintenance, storage, and disposal in accessible formats
• Present safety information in accessible multiple formats

Self-Service Terminals

Self-service terminals, including ATMs, ticket machines, and check-in machines, must:

• Include text-to-speech functionality when the terminal has text input/output
• Allow use of personal headsets/earphones when the terminal delivers audio output
• Support user interaction through voice or touch when requiring timed responses
• Provide visual links to audio/video content
• Prevent visual flashing that could trigger seizures
• Allow use of assistive technologies where needed

E-Readers

E-book readers must include:

• Text-to-speech technology
• Capabilities that allow assistive technology access
• Navigation to content, layout, and functionality
• Dynamic reformatting and flexible settings for text presentation

Consumer Terminal Equipment

Terminal equipment with interactive computing capability used for accessing audiovisual media services must make those components needed for access available to persons with disabilities.

Services covered by the EAA must be provided in a way that maximizes their use by persons with disabilities by:

1. Information about Service Function:
   • Providing information in accessible text and non-text formats
   • Presenting information in an understandable way
   • Presenting information to users in ways they can perceive
2. Website and Application Accessibility:
   • Making websites perceivable, operable, understandable, and robust
   • Including a statement about accessibility compliance
   • Making mobile applications (including mobile services) accessible
3. Support Services:
   • Providing information about the service's accessibility and compatibility with assistive technologies
   • Providing accessible information about service support and alternative accessible solutions

Electronic Communications Services

These services must:

• Provide real-time text in addition to voice communication
• Support total conversation services when providing video alongside voice
• Ensure emergency communications are accessible to persons with disabilities

Audiovisual Media Services

These services must:

• Provide electronic program guides that are perceivable, operable, understandable, and robust
• Ensure accessibility components (accessibility services) are fully transmitted
• Design for accessibility features like subtitles, audio description, spoken subtitles, and sign language interpretation

Transportation Services

Websites and mobile services related to passenger transportation services must:

• Provide accessible information about the service, including accessibility features, in line with international guidelines
• Make electronic identification, security and payment systems accessible

Banking Services

These services must:

• Provide identification methods, electronic signatures, and security features in accessible formats
• Ensure information is understandable with a complexity level not exceeding level B2 (upper intermediate) of the Council of Europe's Common European Framework

E-Books

E-books must:

• Ensure that digital files allow proper formatting, navigation, and access
• Include metadata about accessibility features
• Ensure technical protection measures don't block accessibility features

E-Commerce Services

Online stores and marketplaces must:

• Provide identification, security, and payment methods in accessible formats
• Identify accessibility features of products and services being sold

Annex I also establishes functional performance criteria to serve as guidelines when the technical requirements don't address specific features or functions. These criteria ensure that products and services must be usable by persons:

• Without vision
• With limited vision
• Without perception of color
• Without hearing
• With limited hearing
• Without vocal capability
• With limited manipulation or strength
• With limited reach
• With photosensitive seizures
• With limited cognition
• With privacy concerns related to their disability

The accessibility requirements outlined in Annex I must be systematically implemented by:

• Manufacturers: When designing and producing products
• Service Providers: When developing and providing services
• Importers and Distributors: When selecting products to place on the market

For products, manufacturers must prepare technical documentation demonstrating how the product meets the accessibility requirements. For services, service providers must demonstrate compliance in their service provision.

National authorities in EU Member States are responsible for monitoring compliance with the accessibility requirements and can perform checks to verify conformity.