Annex I to VI
Annex III: Built environment
Twelve aspects of the built environment must be accessible where a member state applies the Article 4(4) option.
- Citation
- Annex III, CELEX 32019L0882 (Directive)
- Binds
- Service providers only where the member state has used the Article 4(4) option for the built environment used by their clients.
- In the instrument
- Annex I to VI
- 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
Annex III sets the accessibility requirements for the built environment in which an in-scope service is provided, where the member state has decided under Article 4(4) that it should apply. The environment covered is the one under the service provider's responsibility and used by clients.
The twelve aspects are: how clients use the outdoor areas and facilities that go with the building; approaches to buildings; use of entrances; use of paths in horizontal circulation; use of paths in vertical circulation; use of rooms by the public; how clients use the equipment and facilities that the service relies on; use of toilets and sanitary facilities; use of exits, evacuation routes and emergency planning; communication and orientation through more than one sensory channel; clients can use the facilities and buildings as they would normally be used; and protection from hazards indoors and outdoors.
The annex is not a general building code. It is a service-access requirement triggered by a national decision, and it reaches the areas clients use, not the whole estate. A provider should first establish whether its member state has exercised the option, then scope the areas in the annex.
In practice
The twelve aspects are a scoping list. Walk the route a client takes from the street to the service counter and mark each aspect on the route. That produces a short list of areas that matter and a defensible boundary. A full building condition survey is a different exercise and may not be what the national option requires.
What to do
- Confirm the member state's Article 4(4) decision for each market.
- Map the twelve aspects to the areas clients actually use.
- Include the evacuation and emergency planning aspect in the safety plan.
- Record the boundary of the provider's responsibility for each area.
Evidence to keep
- The member state measure exercising or declining the option.
- An access audit against the twelve aspects.
- The remediation plan and the date of each completed item.
- The evacuation plan which includes disabled users.
Dates
- 2025-06-28The option can apply as the national measures apply. (Article 4(4), Article 31(2))
Cross-references
Where teams get this wrong
A provider sometimes commissions a full building audit when the national state has not used the option, or when the area is not one clients use. Confirm the legal trigger first, then scope the areas.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Annex III. 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.