Chapter II, accessibility requirements and free movement
Article 4: Accessibility requirements
Products must meet Annex I Section I, and Section II unless they are self-service terminals; services must meet Sections III and IV, with a microenterprise service exemption and a separate 112 duty.
- Citation
- Article 4, CELEX 32019L0882 (Directive)
- Binds
- Economic operators, through the national measures the member states adopt; the article also binds member states to ensure compliance.
- In the instrument
- Chapter II, accessibility requirements and free movement
- 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
Paragraph 1 is the central duty: member states must ensure that economic operators place on the market only products, and provide only services, that meet the accessibility requirements in Annex I, subject to the Article 14 exception. The duty reaches the operator through national law.
Paragraph 2 allocates product requirements. Every product meets Annex I Section I. Every product except a self-service terminal also meets Section II, which adds accessible packaging and installation, maintenance, storage and disposal instructions. Paragraph 3 allocates service requirements. Every service meets Section IV, and every service except urban, suburban and regional transport meets Section III as well.
Paragraph 4 lets a member state decide that the built environment that clients use, where an in-scope service is provided, must meet Annex III. Paragraph 5 exempts microenterprises that provide services from the paragraph 3 requirements and from obligations relating to them. Paragraph 8 requires the answering of 112 emergency communications to meet Annex I Section V, and paragraph 9 allows delegated acts to supplement Annex I.
What to do
- Map every model and service to the exact Annex I section that governs it.
- Apply Section II to products unless the product is a self-service terminal.
- Apply Section III to services except urban, suburban and regional transport, and Section IV to all services.
- Check the microenterprise service exemption separately from the product duties.
- Confirm the member state's Article 4(4) decision before promising a built-environment programme.
Evidence to keep
- An Annex I mapping matrix, one row per model or service, with the section numbers.
- The microenterprise test and its dated evidence where the service exemption is used.
- The member state transposition text for the built-environment decision.
- A separate 112 file where the organisation answers emergency communications.
Dates
- 2025-06-28The requirements apply to products placed and services provided from this date. (Article 2, Article 31(2))
- 2027-06-28Latest date a member state may set for the Article 4(8) 112 duty if it uses the derogation. (Article 31(3))
Cross-references
Where teams get this wrong
The microenterprise exemption sits in the services paragraph. It does not exempt a microenterprise that manufactures or imports a product, and it does not remove the product duties of a company that also sells hardware.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Article 4. 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.