Annex II: Implementation Examples

Annex II of the European Accessibility Act (EAA) provides non-binding examples of possible solutions that contribute to meeting the accessibility requirements outlined in Annex I. These examples serve as practical guidance for economic operators implementing the EAA.

While these examples illustrate ways to achieve compliance, they are not exhaustive nor mandatory. Economic operators can choose alternative approaches to meet the requirements, provided they achieve equivalent or better accessibility outcomes.

This page presents these examples organized by product and service categories, along with additional context and explanations to help with practical implementation.

It's important to understand the legal status of the examples in Annex II:

• Non-binding guidance: The examples provided are illustrative, not prescriptive requirements
• Alternative approaches: Economic operators can implement different solutions that meet the accessibility requirements
• Minimum standards: The examples represent viable approaches but may not represent the most advanced accessibility solutions available
• Evolutionary nature: As technology and accessibility best practices evolve, better approaches may emerge

When evaluating compliance, market surveillance authorities will assess whether the accessibility requirements are met, not whether specific examples from Annex II were followed.

Information Provision

Annex II provides examples for making information accessible:

• Visual information: Providing text alternatives that can be recognized by assistive technologies, such as screen readers
• Non-text content: Providing captions for pre-recorded audio content and audio description for pre-recorded video content
• Text alternatives: Making electronic files readable through assistive technology using proper structure, formatting, and meaningful sequence

User Interface and Design

For making user interfaces accessible, examples include:

• Keyboard operability: Making all functionality available through keyboard interfaces, including for actions that typically require complex gestures
• User control: Providing user control for any automatic changes of content, automatic scrolling, or time limits on reading
• Customization: Making font size, color contrast, and layout adjustable to enhance readability
• Alternatives to color: Using means other than color alone to convey information or indicate an action

Support Services

Annex II also covers support services:

• Accessible documentation: Providing product documentation in accessible electronic formats
• Alternative means: Offering support through multiple channels (e.g., text, voice, video) to accommodate different communication needs
• Clear information: Ensuring support services provide information about the product's accessibility features and compatibility with assistive technologies

Consumer Computer Hardware and Operating Systems

Examples for computer hardware and operating systems include:

• Hardware identification: Providing tactile markings on keys and controls to enable identification by touch
• Operating system interfaces: Offering text-to-speech functionality, screen reader support, and screen magnification
• Adaptive interfaces: Including options for slowing down key repeat rates and adjusting keyboard response times
• Alternative input methods: Supporting speech recognition, eye tracking, or head tracking as alternatives to keyboard and mouse
• Integration with assistive technology: Providing standard connection ports for assistive technology devices

Self-Service Terminals

For self-service terminals (ATMs, ticketing machines, etc.), examples include:

• Voice output: Providing spoken instructions and feedback when a user interacts with the device
• Physical accessibility: Allowing for headphone connection to receive voice guidance privately and securely
• Input flexibility: Allowing users to adjust the time during which inputs are valid, or to confirm inputs before finalizing
• Visual customization: Offering high contrast display modes and visibility enhancement options
• Operational consistency: Ensuring that keypads have a standard layout with tactile indicators

E-Readers

For e-readers, examples of implementation include:

• Text-to-speech: Providing functionality to convert text to spoken output
• Content access: Ensuring that protection measures (e.g., DRM) do not block accessibility features
• Text customization: Allowing users to modify font, size, spacing, and color contrast
• Navigation: Supporting keyboard navigation and structured content to enable navigation by chapter, section, or page
• Dictionary integration: Providing built-in dictionaries to support users with learning disabilities

Smart Devices and Mobile Equipment

For smartphones, tablets, and other smart devices:

• Real-time text capability: Enabling text communication in real-time during voice calls
• High-quality audio: Supporting crystal-clear audio for better understanding of speech
• Visual relay services: Enabling video communication to allow for sign language
• Predictive text input: Providing intelligent word prediction to reduce typing effort
• Haptic feedback: Using vibration patterns to convey information and confirmations
• Built-in accessibility: Including screen readers, voice control, switch control, and other accessibility features

E-Commerce Services

Examples for e-commerce platforms include:

• Accessible product information: Providing detailed, accessible product descriptions including text alternatives for images
• Shopping cart procedures: Ensuring checkout processes are navigable by keyboard and screen readers
• Form identification: Clearly labeling form fields and providing error identification and correction suggestions
• Order confirmation: Providing order confirmations in accessible formats with clear structure
• Product filters: Including accessible filtering options for product searches

Banking Services

For banking services, Annex II examples include:

• Authentication methods: Offering multiple accessible authentication options
• Statement access: Providing bank statements in accessible electronic formats
• Transaction verification: Ensuring that security verification steps are accessible
• Mobile banking: Designing mobile apps with accessibility features and compatibility with assistive technology
• Consistent navigation: Maintaining consistent layouts and navigation patterns across digital banking services

Audiovisual Media Services

For television and streaming services:

• Electronic program guides: Making program information accessible to screen readers
• Closed captions: Providing user-customizable captions for all audiovisual content
• Audio description: Offering audio tracks that describe visual content for viewers with visual impairments
• Sign language: Supporting sign language interpretation for key content
• User controls: Providing accessible mechanisms to enable, disable, or adjust accessibility features

E-Books

Implementation examples for e-book services include:

• Metadata: Including accessibility metadata to help users find accessible content
• Content structure: Using proper heading structure, table of contents, and navigation markers
• Image descriptions: Providing alternative text for all informative images
• MathML: Using Mathematical Markup Language for accessible representation of mathematical formulas
• EPUB format: Providing content in EPUB3 format with accessibility features enabled

Transport Services

For transport-related e-services:

• Journey planning: Providing accessible information about accessible routes, stations, and connection points
• Ticketing services: Ensuring that online ticket purchasing and digital tickets are accessible
• Travel updates: Delivering real-time information about delays or changes in accessible formats
• Map services: Providing accessible map interfaces with text-based location information
• Booking assistance: Making it easy to book special assistance through accessible interfaces

Web Accessibility

Annex II references several technical approaches for web content:

• Semantic HTML: Using appropriate HTML elements for their intended purpose (headings, lists, tables, forms)
• ARIA landmarks: Using ARIA roles to identify regions of a page (navigation, main content, search)
• Focus management: Ensuring visible focus indicators and logical focus order
• Form validation: Providing clear error messages and suggestions for correction
• Responsive design: Creating layouts that adapt to different screen sizes and zoom levels

Mobile Applications

For mobile apps, examples include:

• Platform accessibility APIs: Using the native accessibility frameworks (iOS UIAccessibility, Android AccessibilityService)
• Touch target size: Making interactive elements large enough for users with motor impairments
• Gesture alternatives: Providing alternative means to perform actions that typically require complex gestures
• Screen orientation: Supporting both portrait and landscape orientations
• Consistent navigation: Maintaining predictable patterns across the application

Document Formats

For electronic documents:

• Tagged PDF: Creating PDFs with proper structure tags for headings, lists, tables, and reading order
• Word processing: Using built-in heading styles, alternative text for images, and proper table structure
• Spreadsheets: Adding header rows, avoiding blank cells for formatting, and providing text alternatives for charts
• Presentations: Using unique slide titles, adding alternative text for images, and ensuring high contrast

When applying the examples from Annex II, economic operators should:

Consider Context

• Adapt examples to the specific context and purpose of the product or service
• Consider how examples apply to different types of content within the same product (e.g., text, images, interactive elements)
• Evaluate how examples might need adjustment for industry-specific applications

Follow Technical Standards

• Align implementation with recognized international standards like WCAG for web content
• Leverage platform-specific accessibility guidelines for mobile and desktop applications
• Consider harmonized standards that provide presumption of conformity with the EAA

Test with Real Users

• Validate implementations with people who use assistive technologies
• Include users with different disabilities in testing and feedback processes
• Use this feedback to refine and improve accessibility implementations

Document Implementation Approaches

• Record which examples from Annex II were followed and how they were implemented
• Document any alternative approaches used to meet accessibility requirements
• Maintain this documentation as part of the technical file for conformity assessment

While the examples in Annex II provide valuable guidance, there are important limitations to consider:

• Not comprehensive: The examples don't cover every possible accessibility scenario or requirement
• Technology evolution: As technology advances, better approaches to accessibility may emerge beyond what's described in Annex II
• Minimum vs. optimal: The examples represent viable approaches but not necessarily the most optimal solutions for all contexts
• Integration challenges: Real-world implementation often requires integrating multiple examples and approaches
• Diverse user needs: Users with different disabilities may have different or even conflicting accessibility needs

Economic operators should view Annex II as a starting point, not an exhaustive guide to all accessibility solutions.

Understanding how Annex II relates to other parts of the EAA is important:

• Annex I: The examples in Annex II directly correspond to the mandatory requirements in Annex I, providing practical ways to implement them
• Annex III: When considering the built environment, examples from Annex II may need to be adapted or extended
• Annex IV: When assessing disproportionate burden, the examples in Annex II can help identify reasonable implementation approaches
• Annex V: The conformity assessment process should consider how effectively the examples or equivalent solutions have been implemented
• Fundamental alteration: When considering whether accessibility would require fundamental alteration, comparing with Annex II examples can help determine what constitutes reasonable adaptation

Annex II serves as a bridge between the legal requirements and practical implementation, helping economic operators understand how to apply the EAA in real-world contexts.

Beyond Annex II, economic operators can consult:

• Harmonized standards: Standards that provide presumption of conformity with the EAA
• International guidelines: Resources like the Web Content Accessibility Guidelines (WCAG) and WAI-ARIA
• Industry guidance: Sector-specific accessibility resources published by industry associations
• Platform guidelines: Accessibility documentation provided by major platform vendors (Apple, Google, Microsoft)
• EU guidance: Additional guidance documents published by the European Commission and related bodies

These resources can help expand on the examples provided in Annex II, offering more detailed technical guidance and industry-specific applications.