Annex I, accessibility requirements for products and services
Annex I Section VII: Functional criteria
Eleven functional criteria cover use without vision, with limited vision, colour, hearing, speech, manipulation, reach, seizures, cognition and privacy.
- Citation
- Annex I, Section VII, CELEX 32019L0882 (Directive)
- Binds
- Products and services with functions that the earlier sections leave unaddressed.
- 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 VII is the fallback for functions that the earlier sections leave unaddressed. Those functions must be accessible by meeting the related functional performance criteria. The criteria can replace a specific technical requirement only if applying them meets the accessibility requirement and gives equivalent or better accessibility for foreseeable use.
The eleven criteria are: usage without vision, where a visual mode exists, through at least one mode that does not require vision; usage with limited vision, through at least one mode that works with limited vision; usage without colour perception, through at least one mode that does not require colour; usage without hearing, where an auditory mode exists, through at least one mode that does not require hearing; usage with limited hearing, through enhanced audio; usage without vocal capability, where vocal input is required, through at least one mode that does not need it; usage with limited manipulation or strength, through alternative actions that avoid fine motor control, hand strength or simultaneous controls; usage with limited reach, with operational elements in reach and a mode that works with limited reach and strength; minimising photosensitive seizures; usage with limited cognition, through at least one simpler mode; and privacy, through at least one mode that keeps privacy when accessibility features are used.
The section is a design tool as much as a legal fallback. It gives a product team a way to test a function that the detailed clauses do not name, without inventing a requirement.
What to do
- List the functions that the earlier sections leave unaddressed.
- Test each against the relevant functional criterion.
- Record where a criterion is used as an alternative to a technical requirement.
- Show that the alternative gives equivalent or better accessibility.
Evidence to keep
- A function register with the criterion applied to each.
- The equivalence argument where a criterion replaces a technical clause.
- User testing evidence across the relevant impairments.
Dates
- 2025-06-28The criteria apply to products and services in scope from this date. (Article 4, Article 31(2))
Cross-references
Where teams get this wrong
The criteria are not a menu to pick the easiest route. They are a fallback for unaddressed functions, and using one as an alternative to a named technical requirement needs the equivalence test in the section.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Annex I, Section VII. 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.