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EAAAnnex IEN 301 549

EAA Annex I: functional accessibility requirements

What EAA Annex I requires for products and services, section by section, and how EN 301 549 turns those functional rules into testable checks.

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Pavel Charkasau

The EAA Annex I requirements are the part of the European Accessibility Act that says what "accessible" actually means. The scope rules in the main articles decide who is covered; Annex I of Directive (EU) 2019/882 decides what they have to deliver. It does this in functional terms: the outcomes a product or service must produce for a person with a disability, rather than a list of code-level checks. Annex I is split into sections: general requirements for all products (Section I), packaging and instructions (Section II), general requirements for all services (Section III), extra rules for specific services like banking, e-books, and e-commerce (Section IV), and emergency communications to 112 (Section V). The recurring demands are the same few ideas: give information through more than one sensory channel, make it perceivable and understandable, and let people operate the thing without relying on a single ability. Because the language is functional, Annex I on its own doesn't tell a developer which attribute to set. That gap is filled by EN 301 549, the standard that turns these outcomes into testable requirements. This guide walks each section and shows where the law hands off to the standard.

What is Annex I of the EAA?

Annex I is the accessibility requirements annex of the EAA. The articles of the directive set out who is in scope, what "disproportionate burden" means, and how conformity is assessed. Annex I is the substance those articles point at: the actual requirements a covered product or service has to meet.

It is written as functional performance, not implementation. Section I opens with the general principle that products "must be designed and produced in such a way as to maximise their foreseeable use by persons with disabilities" (Annex I, Section I). That is deliberate. A directive sets the goal and leaves the technical detail to standards, which can be revised without reopening the law. So Annex I tells you the product must let someone perceive and operate it; EN 301 549 tells you a text alternative satisfies success criterion 1.1.1. Read Annex I for what is owed, and the harmonised standard for how to prove it.

What does Annex I require for products?

Section I covers every product in scope — computers, e-readers, smartphones, self-service terminals like ATMs and ticket machines. It has two halves.

The first is information. Labelling, instructions, and warnings must be made available through more than one sensory channel, presented in an understandable way, and be perceivable. Text has to use "fonts of adequate size and suitable shape, taking into account foreseeable conditions of use, and using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs" (Annex I, Section I). And instructions must be provided "in text formats that can be used for generating alternative assistive formats" — the clause that makes a real digital document, rather than a flat scan, the baseline.

The second half is the user interface and functionality design. The product, including its interface, has to "contain features, elements and functions that allow persons with disabilities to access, perceive, operate, understand and control the product." In practice that means communication offered through more than one sensory channel, alternatives to speech input, flexible magnification and contrast, a way to operate the thing without fine motor control, and not depending on colour alone to convey meaning (Annex I, Section I). Section II adds the requirements for packaging and the instructions that come with a product, with a carve-out for self-service terminals.

What does Annex I require for services?

Section III sets the general requirements for services, and its structure mirrors the product rules. A service provider has to ensure the products used to deliver the service are themselves accessible, provide information about how the service works and its accessibility features through more than one sensory channel, and run support services (help desks, call centres, relay services) that can actually tell a customer whether the service works with their assistive technology (Annex I, Section III).

For anything web-facing, one clause does the heavy lifting. Section III requires "making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust." Those four words (perceivable, operable, understandable, robust) are the POUR principles that structure WCAG. The law reaches straight into the web accessibility guidelines without naming them.

Section IV then layers extra duties on specific services. It names seven: electronic communications services, services providing access to audiovisual media, air, bus, rail and waterborne passenger transport, urban and regional transport, consumer banking, e-books, and e-commerce (Annex I, Section IV). E-commerce, for instance, has to provide the accessibility information of the products and services being sold, not just an accessible storefront. Section V handles the answering of emergency communications to 112.

How do Annex I's functional requirements become testable?

This is the join that trips teams up. Annex I says "perceivable" and "operable"; it never says "contrast ratio of at least 4.5:1" or "every control has an accessible name." Those thresholds live in EN 301 549, the harmonised European standard for ICT accessibility. Under Article 15 of the EAA, meeting a harmonised standard whose reference is published in the Official Journal gives you a presumption of conformity with the matching Annex I requirements. In plain terms: conform to the relevant parts of EN 301 549 and you are treated as having met Annex I, unless someone shows otherwise.

For the web, EN 301 549 Chapter 9 incorporates WCAG 2.1 Level AA. So Section III's "perceivable, operable, understandable and robust" resolves to the roughly 50 WCAG success criteria at A and AA. The standard also carries Annex C, a clause-by-clause table you can use to record which requirement is met, partially met, or not applicable — the natural evidence base for an accessibility statement. That mapping is the whole reason "meet EN 301 549" is more useful advice than "read Annex I."

What Annex I does not do

Two honest limits. First, Annex I is functional, so it does not hand you a pass or fail. You cannot certify a product against "maximise their foreseeable use." You demonstrate conformity against EN 301 549's specific clauses and keep the documentation. Anyone selling you a "certified Annex I compliant" badge is selling something the directive doesn't define.

Second, the web slice of Annex I, the WCAG part, can't be fully checked by a scanner. Deque's review of more than 2,000 audits found automated testing identified about 57% of issues by volume, and estimates based on how many success criteria a tool can even evaluate land closer to 30% (Deque). The rest — a sensible focus order, a label that reads correctly to a screen reader, a form you can finish with a keyboard — needs a person. My own view, after mapping a lot of Annex I clauses onto real audits: the requirements aren't hard to understand, they're just easy to under-test. A scanner finds the machine-detectable ones; the functional intent behind Section III is exactly the part a machine can't confirm.

Frequently asked questions

What does Annex I of the EAA cover?

Annex I holds the actual accessibility requirements of the European Accessibility Act. It is split into sections: general requirements for all products (Section I), packaging and instructions (Section II), general requirements for all services (Section III), extra rules for specific services such as banking, e-books, and e-commerce (Section IV), and emergency communications to 112 (Section V).

Are the Annex I requirements the same as WCAG?

Not directly. Annex I is written in functional terms (perceivable, operable, understandable, robust), which are the POUR principles behind WCAG. The exact WCAG success criteria come in through EN 301 549, the harmonised standard whose Chapter 9 incorporates WCAG 2.1 Level AA for web content.

Does Annex I apply to products or services?

Both. Section I and II cover products such as computers, e-readers, and self-service terminals. Section III and IV cover services such as consumer banking, e-commerce, and e-books. A single business can be caught by both if it sells a covered product and provides a covered service.

How do I prove I meet Annex I?

By conforming to EN 301 549 and documenting it. Under Article 15 of the EAA, meeting a harmonised standard cited in the Official Journal gives a presumption of conformity with the Annex I requirements it maps to. For the web, that means testing against WCAG 2.1 AA and recording the result, clause by clause.

Is Annex I legally binding on its own?

Annex I is part of a directive, which each EU member state transposes into national law. The requirements bind once transposed; the directive has applied to new products and services since 28 June 2025. Annex I is the substance the national laws enforce.

Check your site against the Annex I web requirements

The fastest way to see where you stand on the Section III web clause is to measure your key pages against WCAG 2.1 AA, since that is what EN 301 549 asks for on the web. Run a free scan to surface the machine-detectable issues, then work through the manual checks a scanner can't judge. You will have a real baseline and the evidence to write an honest accessibility statement instead of a guess.

Pavel Charkasau, founder, wcagc.com. Last updated 17 August 2026.

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