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EAA · Directive (EU) 2019/882

EAA accessibility requirements — a practical checklist

A practical checklist of what the European Accessibility Act asks for — 33 items, each linked to the part of the Directive it comes from. The item codes are ours; the legal text lives on EUR-Lex and the technical standard at ETSI.

The interface: perceivable, operable, understandable, robust

Annex I sets these outcomes for products in Section I, and Section III(c) asks the same of websites and apps: perceivable, operable, understandable and robust. EN 301 549 tests them through WCAG 2.1 Level AA.

18 items
I.1 · 4 items
I.1.a

Information about how to use the product or service

Provide accessibility information for the product or service in more than one sensory channel — in the product itself or via a website.

How to meet it
  1. Provide clear documentation of all accessibility features
  2. Describe compatibility with common assistive technologies (screen readers, switch devices, voice control)
  3. Make this information available in accessible formats (HTML, accessible PDF)
  4. Include accessibility information in user manuals and help sections
Legal basis: EAA Annex I No WCAG 2.1 success criterion is mapped to this item.
I.1.b

User interface and functionality design

The user interface — interaction, navigation, comprehension — must be operable through more than one sensory channel.

How to meet it
  1. Ensure UI elements are programmatically determinable (proper semantic HTML)
  2. Provide text alternatives for all non-text UI elements
  3. Support multiple input modalities (mouse, keyboard, touch, voice)
  4. Use ARIA roles and properties where native semantics are insufficient
I.1.c

Information, identification and operation functions

Information needed to operate the product, identify elements and perform functions must be perceivable and operable regardless of sensory capability.

How to meet it
  1. Ensure all interactive elements have accessible names
  2. Provide visual and programmatic identification for all controls
  3. Use consistent identification across pages and states
  4. Ensure status messages are communicated to assistive technologies
I.1.d

Perceivable information presentation

Information must be presented in perceivable ways — text alternatives for non-text content, and content that can be presented in different ways without losing meaning.

How to meet it
  1. Provide text alternatives for images, icons, and media
  2. Ensure sufficient colour contrast (4.5:1 for text, 3:1 for large text)
  3. Do not rely on colour alone to convey information
  4. Ensure content is meaningful when linearised or restyled
I.2 · 14 items
I.2.a

Communication services accessibility

Where the service provides communication functions, support real-time text, voice and video in accessible formats.

How to meet it
  1. Support real-time text (RTT) alongside voice communication
  2. Provide captioning for video calls where technically feasible
  3. Ensure communication features work with assistive technologies
  4. Offer alternative communication channels (text, voice, video)
Legal basis: EAA Annex I No WCAG 2.1 success criterion is mapped to this item.
I.2.b

Information about accessibility features

Publish information about the accessibility features of the service and its compatibility with assistive technologies, in accessible formats.

How to meet it
  1. Publish an accessibility statement describing features and known limitations
  2. Document supported assistive technologies and browsers
  3. Provide contact information for accessibility-related inquiries
  4. Keep accessibility documentation up to date with each release
I.2.c

Text content readability and contrast

Text must allow alternative rendering: adjustable font size, sufficient contrast, configurable spacing.

How to meet it
  1. Maintain minimum contrast ratio of 4.5:1 for normal text, 3:1 for large text
  2. Allow text to be resized up to 200% without loss of content or functionality
  3. Support user-defined text spacing (line height, letter spacing, word spacing)
  4. Use relative units (em, rem, %) instead of fixed pixel sizes for text
I.2.d

Content resizing and reflow

Content must reflow to fit the viewport without horizontal scrolling at standard zoom; users must be able to resize without loss of information.

How to meet it
  1. Ensure content reflows at 320px viewport width (equivalent to 400% zoom on 1280px)
  2. Avoid horizontal scrolling for vertical-scrolling content
  3. Use responsive design techniques (CSS Grid, Flexbox)
  4. Test with browser zoom at 200% and 400%
I.2.e

Alternative text for non-text content

Non-text content (images, charts, audio, video) must have text alternatives that serve an equivalent purpose.

How to meet it
  1. Provide alt text for all informative images
  2. Use empty alt="" for decorative images
  3. Provide text transcripts for audio content
  4. Provide captions for video content and audio descriptions where needed
I.2.f

Audio and video alternatives

Audio and video must have synchronised alternatives: captions for audio, audio descriptions for video, transcripts for pre-recorded media.

How to meet it
  1. Provide synchronised captions for all pre-recorded video with audio
  2. Provide audio descriptions for pre-recorded video where visual information is essential
  3. Provide transcripts for pre-recorded audio-only content
  4. Ensure captions are accurate, synchronised, and include speaker identification
I.2.g

Keyboard operability

All functionality must be operable via keyboard without specific keystroke timings; no keyboard traps.

How to meet it
  1. Ensure all interactive elements are reachable and operable via keyboard (Tab, Enter, Space, Arrow keys)
  2. Provide visible focus indicators for all focusable elements
  3. Ensure no keyboard traps exist — users can always navigate away
  4. Support standard keyboard patterns for custom widgets (ARIA Authoring Practices)
I.2.h

Adjustable timing

Where time limits exist, users must be able to turn off, adjust or extend them — unless the time limit is essential.

How to meet it
  1. Allow users to turn off, adjust, or extend any time limits
  2. Warn users before time expires and allow extension
  3. Avoid automatic content updates that cannot be paused or controlled
  4. Exceptions: real-time events, essential time limits (auctions, exams)
I.2.i

Restrictions on flashing content

Content must not flash more than three times per second unless it is below the general flash and red flash thresholds.

How to meet it
  1. Avoid content that flashes more than 3 times per second
  2. If flashing is necessary, ensure it falls below the general flash threshold
  3. Provide warnings before content with potential seizure triggers
  4. Allow users to disable animations and motion effects
I.2.j

Navigation mechanisms

Navigation must be consistent and predictable. Multiple ways to find content. Link purpose must be determinable.

How to meet it
  1. Provide skip navigation links to bypass repeated content
  2. Use descriptive page titles that identify the topic or purpose
  3. Ensure focus order follows a logical, meaningful sequence
  4. Provide multiple navigation mechanisms (menu, search, sitemap)
  5. Use descriptive link text that makes sense out of context
I.2.k

Language identification

The default human language of the page and any language changes within content must be programmatically determinable.

How to meet it
  1. Set the lang attribute on the <html> element
  2. Mark language changes within content using the lang attribute
  3. Use valid IETF BCP 47 language tags (e.g., "en", "de", "fr")
  4. Ensure assistive technologies can detect and switch language pronunciation
I.2.l

Predictable behaviour

Components must behave predictably. Focus must not trigger unexpected context changes. Similar components must be identified consistently.

How to meet it
  1. Do not change context on focus (no unexpected navigation or popups)
  2. Do not change context on input unless the user is advised beforehand
  3. Use consistent navigation and labelling across pages
  4. Identify similar components consistently throughout the service
I.2.m

Input assistance and error handling

Input errors must be detected and described. Labels and instructions must be provided. Error suggestions and prevention for legal or financial data.

How to meet it
  1. Provide visible labels for all form inputs
  2. Identify input errors clearly and provide text descriptions
  3. Suggest corrections when input errors are detected
  4. Allow users to review, correct, and confirm submissions with legal/financial consequences
  5. Use autocomplete attributes for common input fields (name, email, address)
I.2.n

Compatibility with assistive technologies

Content must be compatible with current and future assistive technologies. Name, role and value of UI components must be programmatically determinable.

How to meet it
  1. Use valid, well-formed HTML markup
  2. Ensure all UI components have accessible names and roles
  3. Expose state and property changes to the accessibility API
  4. Test with screen readers (NVDA, JAWS, VoiceOver) and other assistive technologies

Websites and apps — Annex I, Section III

Section III applies to every service the Act covers. Its point (c) is the core requirement for websites and apps; EN 301 549 v3.2.1 turns it into WCAG 2.1 Level AA.

3 items
III.a

WCAG 2.1 Level AA web conformance

Websites and web applications meet WCAG 2.1 Level AA — the web chapter of EN 301 549 v3.2.1 and the usual way to show that Section III(c) is met.

How to meet it
  1. Conduct a full WCAG 2.1 AA audit using industry-standard automated tools and manual testing
  2. Address all Level A and Level AA success criteria
  3. Test with multiple browsers, screen readers, and input devices
  4. Establish a remediation plan for any non-conformances
III.b

Web content accessibility

Web content must be perceivable, operable, understandable and robust across all content types — text, media, forms, dynamic content.

How to meet it
  1. Ensure all page content is accessible to assistive technologies
  2. Provide alternatives for complex content (charts, infographics, data tables)
  3. Make dynamic content updates (AJAX, SPA navigation) accessible
  4. Test single-page application navigation with screen readers
III.c

Mobile web accessibility

Mobile-delivered web content must meet the same accessibility requirements. Touch targets, gestures and responsive behaviour must be accessible.

How to meet it
  1. Ensure touch targets are at least 44x44 CSS pixels
  2. Support both portrait and landscape orientations
  3. Provide alternatives to complex gestures (pinch, swipe, multi-finger)
  4. Test with mobile screen readers (VoiceOver on iOS, TalkBack on Android)

Section IV — Sector-Specific Requirements

Requirements for specific service sectors — electronic communications, audiovisual media, transport, banking, e-books, e-commerce.

7 items
IV.a

E-commerce accessibility

E-commerce services must ensure the entire purchasing journey is accessible — browsing, selection, checkout, payment, confirmation.

How to meet it
  1. Ensure product listings, filters, and sorting are keyboard accessible
  2. Provide accessible product descriptions and image alternatives
  3. Make the entire checkout flow operable with assistive technologies
  4. Ensure payment forms have proper labels and error handling
IV.b

Banking and financial services accessibility

Banking and financial services must make account management, transactions and financial information accessible — without security mechanisms creating barriers.

How to meet it
  1. Ensure authentication mechanisms are accessible (CAPTCHA alternatives, biometric options)
  2. Make transaction flows fully keyboard and screen reader operable
  3. Provide accessible account statements and financial documents
  4. Ensure security features (2FA, session timeouts) accommodate users with disabilities
IV.c

Transport services accessibility

Transport ticketing and traveller information services must be accessible — booking, real-time information, self-service terminals.

How to meet it
  1. Ensure booking and ticket purchase flows are fully accessible
  2. Provide real-time travel information in accessible formats
  3. Make self-service terminals accessible (or provide accessible alternatives)
  4. Ensure mobile apps for transport services meet accessibility requirements
IV.d

Electronic communications services accessibility

Electronic communications services must support real-time text, total conversation where feasible, and accessible customer interfaces — including relay services.

How to meet it
  1. Support real-time text (RTT) in voice communication
  2. Provide total conversation (voice + text + video) where feasible
  3. Ensure customer self-service portals are accessible
  4. Make service configuration and account management accessible
Legal basis: EAA Annex I No WCAG 2.1 success criterion is mapped to this item.
IV.e

Audio-visual media services accessibility

Audio-visual media services must provide access through captions, audio descriptions, and accessible electronic programme guides.

How to meet it
  1. Provide captions/subtitles for all audio-visual content
  2. Provide audio descriptions for visual-only content
  3. Ensure media players are keyboard accessible
  4. Make electronic programme guides (EPGs) accessible
IV.f

E-book and digital publishing accessibility

E-books and digital publications must support text-to-speech, adjustable display, accessible navigation, and DRM that does not block accessibility.

How to meet it
  1. Ensure e-books support text-to-speech and screen reader navigation
  2. Allow font size, spacing, and colour adjustments
  3. Provide alternative descriptions for images and charts
  4. Ensure DRM does not block assistive technology access
IV.g

Electronic identification services (eIDAS-related)

Note: eID is governed by Regulation (EU) 910/2014 and 2024/1183 (eIDAS), not EAA Annex I. It matters here because authentication often gates EAA-covered services.

How to meet it
  1. Ensure login and authentication flows are accessible
  2. Provide alternatives to visual CAPTCHAs
  3. Make multi-factor authentication accessible (not reliant on a single sensory channel)
  4. Ensure digital signature processes are operable with assistive technologies

Article 13 and Annex V — information on how the service meets the requirements

Service providers put this information in their terms and conditions or an equivalent document, in written and oral form, accessible to people with disabilities, for as long as the service runs.

3 items
V.1.a

General description of the service

Describe the service in general terms, in accessible formats (Annex V, point 1(a)).

How to meet it
  1. Say what the service is and who it is for, in plain language
  2. Publish it in the terms and conditions or an equivalent document, as an accessible web page
  3. Offer it in written and oral form, for example by phone or audio on request
  4. Keep it available for as long as the service runs
Legal basis: EAA Article 13 and Annex V No WCAG 2.1 success criterion is mapped to this item.
V.1.b

How the service works

Give the descriptions and explanations needed to understand how the service operates (Annex V, point 1(b)).

How to meet it
  1. Explain the main steps a user goes through: finding, choosing, paying, getting support
  2. Describe the accessibility features the service offers and how to use them
  3. Name the support channels and how to reach them in accessible ways
  4. Update the text whenever the service changes
Legal basis: EAA Article 13 and Annex V No WCAG 2.1 success criterion is mapped to this item.
V.1.c

How the service meets the requirements

Describe how the service meets the relevant accessibility requirements of Annex I; you may refer to harmonised standards such as EN 301 549 (Annex V, points 1(c) and 2).

How to meet it
  1. List the requirements that apply to your service and how each one is met
  2. Name the standard used for testing, such as EN 301 549 v3.2.1 (WCAG 2.1 Level AA)
  3. State known limitations, any disproportionate-burden assessment and the alternatives offered
  4. Give the date of the last assessment and a way to report barriers
Legal basis: EAA Article 13 and Annex V No WCAG 2.1 success criterion is mapped to this item.

Article 14 — Exemptions (disproportionate burden + microenterprise)

Criteria for limiting accessibility requirements under Article 14 EAA, plus the microenterprise exemption from Article 4(5).

2 items
VI.a

Disproportionate burden assessment (Article 14)

Accessibility requirements may be limited where compliance imposes a disproportionate burden — assessed by net cost, organisation size and benefit to people with disabilities.

How to meet it
  1. Document the specific requirements claimed as disproportionate
  2. Provide cost-benefit analysis for each claimed exemption
  3. Reassess disproportionate burden claims when products/services are updated
  4. Keep the assessment for five years, renew it at least every five years for a service, and inform the competent authority
EAA Article 14: disproportionate burden No WCAG 2.1 success criterion is mapped to this item.
VI.b

Microenterprise exemption (Article 4(5))

Microenterprises providing services (fewer than 10 employees AND turnover or balance sheet ≤ €2 million) are exempt from the service accessibility requirements.

How to meet it
  1. Exemption applies only to services, not products
  2. Both criteria must be met: fewer than 10 employees AND turnover/balance sheet under EUR 2 million
  3. Microenterprises are still encouraged to voluntarily comply
  4. If the enterprise grows beyond the thresholds, the exemption no longer applies
EAA Article 4(5): microenterprise exemption No WCAG 2.1 success criterion is mapped to this item.

What no automated tool can check

Automated testing finds only part of the barriers WCAG describes. These checks need a person; do them before you publish an accessibility statement.

  1. Keyboard only

    Put the mouse away and reach every link, button, menu and form field with Tab, Shift+Tab, Enter, Space and the arrow keys. Focus must never get stuck, must follow a logical order and must always be visible.

  2. Screen reader

    Listen to the page with NVDA or JAWS (Windows), VoiceOver (macOS, iOS) or TalkBack (Android). Headings, landmarks, buttons and form fields should be announced with names that make sense.

  3. Quality of text alternatives

    Automation can tell that alternative text exists, not whether it is right. Check that each description says what the image shows or does, and that decorative images are silent.

  4. Captions, transcripts and audio description

    Watch every video with the sound off: captions must be accurate and in sync. Audio needs a transcript, and important visual information needs audio description or a text alternative.

  5. Reading and focus order

    The order in which a screen reader reads the page and the keyboard moves through it must match the visual order and the meaning of the content.

  6. Zoom, reflow and text spacing

    Zoom the browser to 200% and to 400% (a 320 px wide window). No text or function may be lost, nothing may need horizontal scrolling, and increased text spacing must not cut off content.

  7. Links, labels and error messages

    Every link, button and form label says what it does in its context. Error messages name the field, explain what went wrong and say how to fix it.

  8. Colour and sensory cues

    Information is never conveyed by colour, shape, size or position alone. Check contrast on images of text, gradients, and hover and focus states, which automated tools cannot measure reliably.

  9. Motion, timing and flashing

    Carousels, animations and auto-updating content can be paused or stopped, time limits can be turned off or extended, and nothing flashes more than three times per second.

  10. Predictable behaviour

    Focusing or filling in a field never changes the page or opens a new window unexpectedly. Navigation and repeated components appear in the same place and work the same way on every page.

  11. Accessibility statement and feedback

    Publish an accessibility statement that lists known limitations and gives users a working way to report barriers and get a reply.

About this checklist

This is RankProof’s checklist, not the Directive’s own numbering: codes such as I.2.c are our item IDs. Items are grouped by the part of Directive (EU) 2019/882 they come from — the interface outcomes of Annex I (Section I for products, Section III for services), the extra requirements for specific services (Annex I, Section IV), the information required by Article 13 and Annex V, and the exemptions in Articles 14 and 4(5). The WCAG 2.1 Level AA mapping follows EN 301 549 v3.2.1. Always check the official text on EUR-Lex.

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