Directive (EU) 2019/882
Article 14 · Annex VI
Article 14 disproportionate burden assessment
Not a defence you raise when someone complains. Article 14 is an assessment you carry out in advance, document, retain five years, renew, and notify to your market surveillance authority. This generates that document.
It needs no accessibility testing. Annex VI is ratios of costs to costs and costs to turnover, plus a benefit comparison, which is why this is the cheapest piece of EAA compliance work you can start.