European Accessibility Act · Annex I Section IV

Additional requirements for specific services

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Annex I Section IV: Additional accessibility requirements for specific services

service provider · subject kind service · Annex I Section IV

The provision of services in order to maximise their foreseeable use by persons with disabilities, shall be achieved by including functions, practices, policies and procedures and alterations in the operation of the service targeted to address the needs of persons with disabilities and ensure interoperability with assistive technologies:

How to satisfy it: Article 4(3) second subparagraph applies this to ALL services, with no transport carve-out. Article 4(5) still exempts microenterprises.

Annex I Section IV on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (a)

service provider · subject kind service · Annex I Section IV (a)

Electronic communications services, including emergency communications referred to in Article 109(2) of Directive (EU) 2018/1972:

Annex I Section IV (a) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (a)(i)

service provider · subject kind service · Annex I Section IV (a)(i)

providing real time text in addition to voice communication;

Annex I Section IV (a)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (a)(ii)

service provider · subject kind service · Annex I Section IV (a)(ii)

providing total conversation where video is provided in addition to voice communication;

Annex I Section IV (a)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (a)(iii)

service provider · subject kind service · Annex I Section IV (a)(iii)

ensuring that emergency communications using voice, text (including real time text) is synchronised and where video is provided is also synchronised as total conversation and is transmitted by the electronic communications service providers to the most appropriate PSAP.

Annex I Section IV (a)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (b)

service provider · subject kind service · Annex I Section IV (b)

Services providing access to audiovisual media services:

Annex I Section IV (b) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (b)(i)

service provider · subject kind service · Annex I Section IV (b)(i)

providing electronic programme guides (EPGs) which are perceivable, operable, understandable and robust and provide information about the availability of accessibility;

Annex I Section IV (b)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (b)(ii)

service provider · subject kind service · Annex I Section IV (b)(ii)

ensuring that the accessibility components (access services) of the audiovisual media services such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation are fully transmitted with adequate quality for accurate display, and synchronised with sound and video, while allowing for user control of their display and use.

Annex I Section IV (b)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (c)

service provider · subject kind service · Annex I Section IV (c)

Air, bus, rail and waterborne passenger transport services except for urban and suburban transport services and regional transport services:

Annex I Section IV (c) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (c)(i)

service provider · subject kind service · Annex I Section IV (c)(i)

ensuring the provision of information on the accessibility of vehicles, the surrounding infrastructure and the built environment and on assistance for persons with disabilities;

Annex I Section IV (c)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (c)(ii)

service provider · subject kind service · Annex I Section IV (c)(ii)

ensuring the provision of information about smart ticketing (electronic reservation, booking of tickets, etc.), real-time travel information (timetables, information about traffic disruptions, connecting services, onwards travel with other transport modes, etc.), and additional service information (e.g. staffing of stations, lifts that are out of order or services that are temporarily unavailable).

Annex I Section IV (c)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (d)

service provider · subject kind service · Annex I Section IV (d)

Urban and suburban transport services and regional transport services: ensuring the accessibility of self-service terminals used in the provision of the service in accordance with Section I of this Annex.

How to satisfy it: The only Section IV limb that binds the services Article 4(3) carves OUT of Section III. Urban, suburban and regional transport still owe self-service terminal accessibility.

Annex I Section IV (d) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (e)

service provider · subject kind service · Annex I Section IV (e)

Consumer banking services:

How to satisfy it: Point (ii) sets a plain-language ceiling by name: no harder than CEFR level B2. That is a rare, testable drafting choice and almost nobody implements it.

Annex I Section IV (e) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (e)(i)

service provider · subject kind service · Annex I Section IV (e)(i)

providing identification methods, electronic signatures, security, and payment services which are perceivable, operable, understandable and robust;

Annex I Section IV (e)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (e)(ii)

service provider · subject kind service · Annex I Section IV (e)(ii)

ensuring that the information is understandable, without exceeding a level of complexity superior to level B2 (upper intermediate) of the Council of Europe’s Common European Framework of Reference for Languages.

Annex I Section IV (e)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)

service provider · subject kind service · Annex I Section IV (f)

E-books:

How to satisfy it: Point (v) is metadata discoverability, and point (vi) forbids DRM that blocks accessibility features. Both are EPUB-shaped duties the web-testing tools never look at.

Annex I Section IV (f) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)(i)

service provider · subject kind service · Annex I Section IV (f)(i)

ensuring that, when an e-book contains audio in addition to text, it then provides synchronised text and audio;

Annex I Section IV (f)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)(ii)

service provider · subject kind service · Annex I Section IV (f)(ii)

ensuring that e-book digital files do not prevent assistive technology from operating properly;

Annex I Section IV (f)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)(iii)

service provider · subject kind service · Annex I Section IV (f)(iii)

ensuring access to the content, the navigation of the file content and layout including dynamic layout, the provision of the structure, flexibility and choice in the presentation of the content;

Annex I Section IV (f)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)(iv)

service provider · subject kind service · Annex I Section IV (f)(iv)

allowing alternative renditions of the content and its interoperability with a variety of assistive technologies, in such a way that it is perceivable, understandable, operable and robust;

Annex I Section IV (f)(iv) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)(v)

service provider · subject kind service · Annex I Section IV (f)(v)

making them discoverable by providing information through metadata about their accessibility features;

Annex I Section IV (f)(v) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (f)(vi)

service provider · subject kind service · Annex I Section IV (f)(vi)

ensuring that digital rights management measures do not block accessibility features.

Annex I Section IV (f)(vi) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (g)

service provider · subject kind service · Annex I Section IV (g)

E-Commerce services:

How to satisfy it: The largest in-scope population and the worst-performing segment. Point (ii) covers identification, security and payment delivered AS A SERVICE rather than as a product, which is what pulls a hosted checkout in.

Annex I Section IV (g) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (g)(i)

service provider · subject kind service · Annex I Section IV (g)(i)

providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator;

Annex I Section IV (g)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (g)(ii)

service provider · subject kind service · Annex I Section IV (g)(ii)

ensuring the accessibility of the functionality for identification, security and payment when delivered as part of a service instead of a product by making it perceivable, operable, understandable and robust;

Annex I Section IV (g)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex I Section IV (g)(iii)

service provider · subject kind service · Annex I Section IV (g)(iii)

providing identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust.

Annex I Section IV (g)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

No harmonised standard is cited in the Official Journal under this Directive, so the Article 15(1) presumption of conformity is available to nobody. EN 301 549 is harmonised under Directive (EU) 2016/2102, the Web Accessibility Directive, and not under this one. Conformity is demonstrated against Annex I directly.

Every quoted requirement on this page is verbatim Official Journal text. The surrounding guidance is Legalithm’s commentary and is not regulation. This page states the obligation and its legal basis; it is not legal advice, and the corpus has not been reviewed by counsel.