Criteria for assessment of disproportionate burden

Annex VI: Criteria for assessment of disproportionate burden

all operators · Annex VI

Criteria to carry out and document the assessment:

How to satisfy it: Three criteria. All financial or organisational, so this artefact needs NO accessibility testing and is authorable and sellable ahead of any Annex I work.

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

Annex VI (1)

all operators · Annex VI (1)

Ratio of the net costs of compliance with accessibility requirements to the overall costs (operating and capital expenditures) of manufacturing, distributing or importing the product or providing the service for the economic operators. Elements to use to assess the net costs of compliance with accessibility requirements:

How to satisfy it: Turnover is not the denominator here — overall operating and capital expenditure is. Criterion 3 is the turnover ratio.

Annex VI (1) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(a)

all operators · Annex VI (1)(a)

criteria related to one-off organisational costs to take into account in the assessment:

Annex VI (1)(a) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(a)(i)

all operators · Annex VI (1)(a)(i)

costs related to additional human resources with accessibility expertise;

Annex VI (1)(a)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(a)(ii)

all operators · Annex VI (1)(a)(ii)

costs related to training human resources and acquiring competences on accessibility;

Annex VI (1)(a)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(a)(iii)

all operators · Annex VI (1)(a)(iii)

costs of development of a new process for including accessibility in the product development or service provision;

Annex VI (1)(a)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(a)(iv)

all operators · Annex VI (1)(a)(iv)

costs related to development of guidance material on accessibility;

Annex VI (1)(a)(iv) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(a)(v)

all operators · Annex VI (1)(a)(v)

one-off costs of understanding the legislation on accessibility;

Annex VI (1)(a)(v) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(b)

all operators · Annex VI (1)(b)

criteria related to on-going production and development costs to take into account in the assessment:

Annex VI (1)(b) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(b)(i)

all operators · Annex VI (1)(b)(i)

costs related to the design of the accessibility features of the product or service;

Annex VI (1)(b)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(b)(ii)

all operators · Annex VI (1)(b)(ii)

costs incurred in the manufacturing processes;

Annex VI (1)(b)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(b)(iii)

all operators · Annex VI (1)(b)(iii)

costs related to testing the product or service for accessibility;

Annex VI (1)(b)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (1)(b)(iv)

all operators · Annex VI (1)(b)(iv)

costs related to establishing documentation.

Annex VI (1)(b)(iv) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (2)

all operators · Annex VI (2)

The estimated costs and benefits for the economic operators, including production processes and investments, in relation to the estimated benefit for persons with disabilities, taking into account the amount and frequency of use of the specific product or service.

How to satisfy it: The benefit comparison the operator does not control: it is weighed against the estimated benefit to persons with disabilities, by amount and frequency of use.

Annex VI (2) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)

all operators · Annex VI (3)

Ratio of the net costs of compliance with accessibility requirements to the net turnover of the economic operator. Elements to use to assess the net costs of compliance with accessibility requirements:

How to satisfy it: Net compliance cost against net turnover, which is why a profitable company cannot argue absolute cost.

Annex VI (3) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(a)

all operators · Annex VI (3)(a)

criteria related to one-off organisational costs to take into account in the assessment:

Annex VI (3)(a) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(a)(i)

all operators · Annex VI (3)(a)(i)

costs related to additional human resources with accessibility expertise;

Annex VI (3)(a)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(a)(ii)

all operators · Annex VI (3)(a)(ii)

costs related to training human resources and acquiring competences on accessibility;

Annex VI (3)(a)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(a)(iii)

all operators · Annex VI (3)(a)(iii)

costs of development of a new process for including accessibility in the product development or service provision;

Annex VI (3)(a)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(a)(iv)

all operators · Annex VI (3)(a)(iv)

costs related to development of guidance material on accessibility;

Annex VI (3)(a)(iv) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(a)(v)

all operators · Annex VI (3)(a)(v)

one off costs of understanding the legislation on accessibility;

Annex VI (3)(a)(v) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(b)

all operators · Annex VI (3)(b)

criteria related to on-going production and development costs to take into account in the assessment:

Annex VI (3)(b) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(b)(i)

all operators · Annex VI (3)(b)(i)

costs related to the design of the accessibility features of the product or service;

Annex VI (3)(b)(i) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(b)(ii)

all operators · Annex VI (3)(b)(ii)

costs incurred in the manufacturing processes;

Annex VI (3)(b)(ii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(b)(iii)

all operators · Annex VI (3)(b)(iii)

costs related to testing the product or service for accessibility;

Annex VI (3)(b)(iii) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882

Annex VI (3)(b)(iv)

all operators · Annex VI (3)(b)(iv)

costs related to establishing documentation.

Annex VI (3)(b)(iv) on EUR-Lex · as of 2026-08-14 · Directive (EU) 2019/882