Annex III: Requirements for Built Environment

Annex III of the European Accessibility Act establishes accessibility requirements for the built environment where services covered by the EAA are provided to the public. These requirements aim to ensure that the physical spaces where services are delivered are accessible to persons with disabilities, maximizing their foreseeable use.

It's important to note that Member States can choose whether to require compliance with these built environment requirements. If a Member State decides to require compliance, the built environment where the service is provided must conform to the requirements outlined in this annex.

The requirements in Annex III apply to:

• Service areas: Physical locations where services falling under the scope of the EAA are provided to the public
• Service infrastructure: Buildings, facilities, and environments designed for public access where covered services are delivered
• New constructions: Requirements typically apply to newly constructed facilities or major renovations
• Existing buildings: When Member States require it, the requirements may also apply to existing facilities (often with reasonable adaptation periods)

The built environment requirements focus on ensuring that persons with various disabilities can access and use the physical spaces where they receive services covered by the EAA.

1. Use of Related Spaces and Facilities

For the independent use of spaces and facilities open to the public:

• Adjacent outdoor areas: Design outdoor areas and facilities that are under the responsibility of the service provider to be accessible
• Approaches to buildings: Provide accessible paths to buildings from public areas, including parking facilities and public transportation stops
• Service delivery areas: Ensure all areas where the service is delivered are designed for independent navigation and use

2. Access to Building Entrances

To ensure accessible building entrances:

• Step-free access: Provide at least one accessible, step-free entrance route
• Door clearance: Ensure doorways have sufficient width for wheelchair users
• Door operation: Install doors that can be opened with minimal force or provide automated door systems
• Thresholds: Design thresholds to be level or with minimal height differences to prevent tripping hazards
• Clear markings: Make entrances clearly visible through appropriate visual contrast and lighting

3. Horizontal Circulation

For accessible horizontal circulation within buildings:

• Corridor width: Design corridors and passageways with sufficient width for wheelchair users, including passing spaces where needed
• Floor surfaces: Provide stable, firm, and slip-resistant floor surfaces
• Level changes: Identify any small level changes with visual contrast and tactile warnings
• Clear space: Ensure adequate clear space for maneuvering, particularly at doors and intersections
• Wayfinding: Implement consistent and accessible wayfinding systems with visual, tactile, and where appropriate, audible information

4. Vertical Circulation

For accessible vertical circulation between building levels:

• Accessible routes: Provide accessible routes between all floors where services are delivered
• Elevators: Install accessible elevators with appropriate dimensions, controls at accessible heights, and audible and visual signals
• Ramps: Where necessary, provide ramps with appropriate slope, width, non-slip surfaces, handrails, and landing areas
• Stairs: Design stairs with consistent step dimensions, visual contrast on step edges, and handrails on both sides
• Platform lifts: Where appropriate, install platform lifts as an alternative vertical circulation option

5. Service Counters and Information Points

For accessible service delivery points:

• Counter heights: Provide service counters with sections at appropriate heights for both standing and seated users
• Clear approach: Ensure sufficient clear space for wheelchair users to approach and use service counters
• Visual contrast: Design service areas with adequate visual contrast to help those with visual impairments
• Induction loops: Install hearing enhancement systems (such as induction loops) at service counters to assist people with hearing impairments
• Lighting: Provide appropriate lighting to facilitate lip-reading and sign language interpretation

6. Accessible Facilities

For accessible facilities within service areas:

• Toilets: Provide accessible toilet facilities with appropriate dimensions, fixtures at suitable heights, and emergency call systems
• Waiting areas: Design waiting spaces with accessible seating options and space for wheelchair users
• Self-service equipment: Ensure that any self-service machines or kiosks are accessible to people with various disabilities
• Signage: Install clear, consistent, and accessible signage throughout the facility
• Acoustic environment: Design spaces with appropriate acoustic properties to minimize background noise and echo

The built environment must include accessible information and communication elements:

• Signage: Provide clear, legible signage with adequate contrast, appropriate sizing, and consistent placement
• Wayfinding: Implement integrated wayfinding systems using visual, tactile, and where appropriate, audible information
• Tactile information: Include tactile signage and tactile maps at key decision points for people with visual impairments
• Alarms: Install emergency alarm systems that provide both visual and audible signals
• Acoustic information: Design public address systems to be clear and understandable, with minimal echo or distortion
• Digital interfaces: Ensure that any digital interfaces in the built environment (such as information kiosks) meet accessibility requirements

Accessible emergency provisions must include:

• Evacuation routes: Design accessible emergency evacuation routes with appropriate signage
• Areas of refuge: Provide designated areas of refuge where persons with disabilities can wait safely for assistance
• Two-way communication: Install accessible two-way communication systems in areas of refuge
• Visual and audible alarms: Ensure fire alarms and emergency notifications include both visual (flashing lights) and audible elements
• Clear evacuation instructions: Provide evacuation instructions in accessible formats, including large print and simple language
• Emergency lighting: Install adequate emergency lighting along evacuation routes

Annex III requirements can be met by referring to various technical standards and specifications:

• European standards: EN 17210 "Accessibility and usability of the built environment - Functional requirements"
• ISO standards: ISO 21542 "Building construction - Accessibility and usability of the built environment"
• National building codes: Member States' technical regulations on accessibility in the built environment
• CEN/CENELEC standards: European standardization organizations' technical specifications for accessible built environments
• Harmonized standards: Standards developed specifically to support EAA implementation (when available)

While following these standards doesn't automatically guarantee compliance with Annex III, they provide valuable guidance and established best practices that can help organizations implement the accessibility requirements effectively.

Service providers can adopt various approaches to implement Annex III requirements:

• Access audits: Conduct comprehensive accessibility audits of existing facilities to identify barriers
• Phased implementation: Develop a prioritized, phased approach to addressing accessibility improvements
• Universal design principles: Apply universal design principles in new construction and renovations
• Staff training: Train facility management and staff on accessibility features and how to assist persons with disabilities
• Feedback mechanisms: Establish systems for users to report accessibility issues and suggest improvements
• Consultation: Involve disability organizations and experts in planning and implementing accessibility improvements

Implementation of Annex III requirements may vary across Member States:

• Optional implementation: Member States decide whether to require compliance with the built environment requirements
• Varying standards: Member States may have different national accessibility standards for the built environment
• Implementation timelines: Transition periods for complying with built environment requirements may vary
• Scope differences: Some Member States may apply the requirements to a broader or narrower range of services
• Enforcement mechanisms: The approach to monitoring and enforcing compliance may differ between countries

Service providers operating across multiple Member States should be aware of these variations and ensure compliance with the specific requirements in each country where they operate.

Annex III works in conjunction with other parts of the EAA:

• Annex I (Accessibility Requirements): While Annex I focuses on product and service accessibility, Annex III addresses the physical environment where those services are provided
• Annex II (Examples of Implementation): Some examples in Annex II may relate to physical interfaces or elements relevant to the built environment
• Annex IV and VI (Disproportionate Burden): The assessment of disproportionate burden may also apply to built environment requirements
• Annex V (Conformity Assessment): The conformity assessment process may need to consider built environment aspects for service providers

Understanding the interrelation between these annexes helps service providers develop comprehensive accessibility strategies that address both digital and physical aspects of service delivery.