Annex I, accessibility requirements for products and services
Annex I Section I: General product duties
Products must be designed for foreseeable use by persons with disabilities, with usable information, a flexible interface and support services where available.
- Citation
- Annex I, Section I, CELEX 32019L0882 (Directive)
- Binds
- Every product in Article 2(1), including self-service terminals.
- In the instrument
- Annex I, accessibility requirements for products and services
- Applies from
- 28 June 2025 for products placed and services provided from that date (Article 31(2)). The Article 4(8) 112 duty may be deferred to 28 June 2027 where a member state uses Article 31(3).
- Source
- EUR-Lex, CELEX 32019L0882
What it requires
The opening sentence sets the design test: products must be designed and produced to be as usable as possible by disabled people in the ways they can be expected to be used, and, where possible, must carry accessible information on how they work and on their accessibility features.
Point 1 covers information. Information on the product itself, such as labelling, instructions and warnings, must reach the user through more than one sensory channel, be understandable and perceivable, use type that is large enough and shaped for the conditions of use, have sufficient contrast and let the reader widen the spacing between characters, lines and blocks. Instructions not carried on the product, for example on a website, must be public before the product is first supplied, meet the same presentation qualities, be in text formats that can generate alternative assistive formats, give an alternative presentation of non-text content, describe the interface and the disability-related functions against point 2, and describe the software and hardware interfaces with assistive devices, including the devices tested with the product.
Point 2 covers the interface and functionality. The product must allow access, perception, operation, understanding and control through more than one sensory channel; alternatives to speech and vocal input; flexible magnification, brightness and contrast and interoperability with navigation aids; an alternative to colour and to audible signals; volume and speed control with enhanced audio and reduced interference; sequential control, alternatives to fine motor control, no simultaneous controls and tactilely discernible parts; no extensive reach or great strength; no triggering of photosensitive seizures; privacy when accessibility features are used; an alternative to biometric identification; consistent behaviour and flexible time; and interfaces with assistive technology. Point 2(o) adds sector rules for self-service terminals, e-readers, consumer terminal equipment for electronic communications and consumer terminal equipment for audiovisual media. Point 3 requires support services, where available, to give accessibility and compatibility information in accessible modes.
What to do
- Design the product and its interface against every point in Section I that applies.
- Publish instructions and accessibility information before the product is placed.
- Describe the interface and functions against point 2, feature by feature.
- List the assistive devices the product was tested with.
- Apply the sector rules in point 2(o) for terminals, e-readers and terminal equipment.
- Give support services accessible ways to answer accessibility questions.
Evidence to keep
- A requirement-by-requirement design file mapped to Section I points 1, 2 and 3.
- The public instructions and accessibility information.
- The assistive-device test list with versions and results.
- User testing that includes people with different disabilities.
- Support service scripts and the accessible channels offered.
Dates
- 2025-06-28Section I applies to products placed on the market from this date. (Article 2(1), Article 4(2))
Cross-references
Where teams get this wrong
Point 1(b)(vii) to (ix) is often skipped. It requires the instructions to describe the interface and the disability-related functions and to list the assistive devices tested, which is a documentation duty as well as a design one.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Annex I, Section I. Check it yourself: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882. This page states the provision in our own words and is not legal advice; it does not certify any product or service.