Annex I, accessibility requirements for products and services
Annex I Section IV: Specific service duties
Seven service groups carry extra duties, from real time text and total conversation to CEFR B2 banking information and DRM that does not block accessibility.
- Citation
- Annex I, Section IV, CELEX 32019L0882 (Directive)
- Binds
- Electronic communications, audiovisual access, passenger transport, urban transport terminals, consumer banking, e-books and e-commerce.
- 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
Section IV adds sector duties to the Section III baseline. Point (a) covers electronic communications, including emergency communications: real time text alongside voice, total conversation where video is offered, and synchronised voice, text and video transmitted to the most appropriate public safety answering point.
Point (b) covers services giving access to audiovisual media: programme guides that people can perceive, operate, understand and rely on, and that show what accessibility is offered, and full transmission of subtitles, audio description, spoken subtitles and sign language interpretation with adequate quality, synchronisation and user control. Point (c) covers air, bus, rail and water passenger transport other than urban, suburban and regional services: information on the accessibility of vehicles, surrounding infrastructure, the built environment and assistance, plus smart ticketing, real time travel information and service information. Point (d) covers urban, suburban and regional transport and requires accessible self-service terminals under Section I.
Point (e) covers consumer banking: identification, electronic signatures, security and payment services must be perceivable, operable, understandable and robust, and information must not exceed CEFR level B2. Point (f) covers e-books: synchronised text and audio where audio is included, files that do not prevent assistive technology from working, access to content, navigation and layout including dynamic layout, alternative renditions and interoperability, metadata that makes accessibility discoverable, and digital rights management that does not block accessibility features. Point (g) covers e-commerce: accessibility information for the products and services sold where the responsible operator supplies it, accessible identification, security and payment functionality delivered as part of the service, and identification, signature and payment services that meet the four qualities.
What to do
- Identify the sector point that applies and treat it as additional to Section III.
- Test the whole journey, including third-party payment and identity steps.
- Keep the sector-specific evidence separate so an authority can find it.
- Review the sector point when the service changes.
Evidence to keep
- A sector clause map with the test performed for each clause.
- For banking, the CEFR B2 review of customer information.
- For e-books, the metadata record and the DRM accessibility test.
- For transport, the information artefacts and terminal audit.
- For communications, the real time text and total conversation test.
Dates
- 2025-06-28Section IV applies to services provided from this date. (Article 4(3), Article 31(2))
Cross-references
Where teams get this wrong
A team often tests the website and stops. Section IV reaches the checkout, the identity check, the payment terminal, the e-book file and the travel information feed, and those are usually run by other suppliers.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Annex I, Section IV. 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.