Article 4(1): Only compliant products and services may be placed or provided
all operators · Article 4(1)
Member States shall ensure, in accordance with paragraphs 2, 3 and 5 of this Article and subject to Article 14, that economic operators only place on the market products and only provide services that comply with the accessibility requirements set out in Annex I.
How to satisfy it: The source of every operator duty in the Directive. Addressed to Member States, but what it requires them to ensure is that economic operators place and provide only compliant products and services. Subject to Article 14 and to the paragraph 5 microenterprise exemption.
Article 4(2): Products comply with Annex I Sections I and II
subject kind product · Article 4(2)
All products shall comply with the accessibility requirements set out in Section I of Annex I. All products, except for self-service terminals, shall comply with the accessibility requirements set out in Section II of Annex I.
How to satisfy it: Two limbs in one paragraph: ALL products owe Section I, and all products EXCEPT self-service terminals also owe Section II. There is no microenterprise exemption on the product side.
Article 4(3): Services comply with Annex I Sections III and IV
subject kind service · Article 4(3)
Without prejudice to paragraph 5 of this Article, all services, except for urban and suburban transport services and regional transport services, shall comply with the accessibility requirements set out in Section III of Annex I. Without prejudice to paragraph 5 of this Article, all services shall comply with the accessibility requirements set out in Section IV of Annex I.
How to satisfy it: Two limbs: all services EXCEPT urban, suburban and regional transport owe Section III, and ALL services owe Section IV. Both subparagraphs sit inside paragraph 3, which is why the Article 4(5) microenterprise exemption reaches both.
Article 4(4): Member States may extend to the built environment
member state · Article 4(4)
Member States may decide, in the light of national conditions, that the built environment used by clients of services covered by this Directive shall comply with the accessibility requirements set out in Annex III, in order to maximise their use by persons with disabilities.
How to satisfy it: A national option, not an operator duty. Where a Member State exercises it, Annex III applies to the built environment used by clients of covered services.
Article 4(5): Microenterprises providing services are exempt
subject kind service · Article 4(5)
Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements.
How to satisfy it: Services only. It clears the paragraph 3 requirements AND any obligation relating to compliance with them, so Article 13 and Annex V go with Sections III and IV. It does NOT reach Article 14, Annex VI or Section VII, and there is no equivalent exemption for products.
Article 4(6): Member States provide guidelines and tools to microenterprises
member state · Article 4(6)
Member States shall provide guidelines and tools to microenterprises to facilitate the application of the national measures transposing this Directive. Member States shall develop those tools in consultation with relevant stakeholders.
Article 4(7): Member States may point operators at the Annex II examples
member state · Article 4(7)
Member States may inform economic operators of the indicative examples, contained in Annex II, of possible solutions that contribute to meeting the accessibility requirements in Annex I.
How to satisfy it: Annex II is indicative and non-binding by its own heading. Nothing in it is authored as an obligation.
Article 4(8): Member States ensure 112 answering meets Annex I Section V
member state · Article 4(8)
Member States shall ensure that the answering of emergency communications to the single European emergency number ‘112’ by the most appropriate PSAP, shall comply with the specific accessibility requirements set out in Section V of Annex I in the manner best suited to the national organisation of emergency systems.
How to satisfy it: The duty-bearer is the Member State and its most appropriate PSAP, not an economic operator. Article 31(3) lets a Member State defer this to 28 June 2027.
Article 4(9): Commission may supplement Annex I by delegated act
commission · Article 4(9)
The Commission is empowered to adopt delegated acts in accordance with Article 26 to supplement Annex I by further specifying the accessibility requirements that, by their very nature, cannot produce their intended effect unless they are further specified in binding legal acts of the Union, such as requirements related to interoperability.
How to satisfy it: Never used. No delegated act supplementing Annex I has been adopted, so Annex I stands as enacted.
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.
