Annex VI: Disproportionate Burden Calculator
Estimate if the cost of compliance constitutes a disproportionate burden under Article 14 / Annex VI.
Legal basis — disproportionate burden exception
- Directive (EU) 2016/2102 — Public Sector Accessibility DirectiveArticle 5 — Disproportionate burden
⚠️ LEGAL TEXT PENDING — paste Article 5 verbatim from the sourceUrl. Defines the disproportionate-burden exception: public-sector bodies may be relieved of requirements that impose undue burden, per an assessment taking into account specified factors. Placeholder only.
Retrieved 2026-04-24View on EUR-Lex ↗ - S.I. No. 636/2023 — European Union (Accessibility Requirements of Products and Services) Regulations 2023Regulation 5 — Accessibility requirements
Read the verbatim text (1700+ characters) ▾Hide verbatim text ▴
5. (1) Subject to Regulation 15, economic operators shall only – (a) place on the market products, or (b) provide services, that comply with the accessibility requirements specified in this Regulation in relation to the products or service concerned. (2) Products – (a) shall comply with the accessibility requirements specified in Part 1 of Schedule 1, and (b) other than self-service terminals, shall comply with the accessibility requirements specified in Part 2 of Schedule 1. (3) Subject to paragraph (4), services – (a) other than urban and suburban transport services and regional transport services, shall comply with the accessibility requirements specified in Part 3 of Schedule 1, and (b) shall comply with the accessibility requirements specified in Part 4 of Schedule 1. (4) Paragraph (3) and Regulation 14 shall not apply to a service provided by a microenterprise. (5) The answering of emergency communications to the single European emergency number ‘112’ by the most appropriate PSAP shall comply with the specific accessibility requirements specified in Part 5 of Schedule 1. (6) The market surveillance authority shall, for the purpose of facilitating the application of these Regulations, provide guidelines and tools to microenterprises. (7) The market surveillance authority, in developing the tools referred to in paragraph (6) – (a) shall consult with relevant stakeholders, and (b) may, where it considers it necessary to do so, request the assistance of the National Disability Authority or a compliance authority. (8) The National Disability Authority or the compliance authority concerned shall comply with a request made to it under paragraph (7)(b).
Retrieved 2026-04-24View on Irish Statute Book ↗Transposes Directive (EU) 2019/882 — European Accessibility Act, Article 4 — EUR-Lex ↗ (official English text pending verbatim ingestion).
What is this?
This tool helps you assess whether achieving full accessibility compliance would be a 'disproportionate burden' on your organisation. The EAA allows limited exemptions where the cost of compliance genuinely outweighs the benefit — but the bar is high and the exemption must be formally documented.
When do I need this?
Use this only when you believe a specific accessibility requirement would be genuinely unachievable due to financial or technical constraints. Do not use it to avoid compliance generally.
- 1Enter your organisation's financial details — The calculation requires your annual turnover, net profit, and number of employees. These determine your financial capacity.
- 2Describe the specific requirement — Name the specific accessibility requirement you believe may be disproportionate. Be precise — 'full WCAG compliance' is not a valid burden claim; a specific technical feature may be.
- 3Enter the estimated cost of compliance — Get a realistic quote for implementing the requirement. Use the tool's cost breakdown fields.
- 4Review the assessment — The tool calculates whether your claimed burden is likely to be accepted by a regulator. If the score is low, reconsider whether a full exemption is justified.
- 5Export your assessment — Download the full assessment document. You must file this formally and review it annually.
Step 1: Financial Data (Annex VI a)
⚠ Article 14(7) requires you to notify this authority before relying on a disproportionate burden exemption. The assessment must be available for inspection on request.
Regulators can request evidence supporting your cost estimates. Reference the documents here so they appear in the exported assessment.
Step 2: Qualitative Factors (Annex VI b–f)
Annex VI (e) specifically requires analysis of frequency and duration of use by persons with disabilities — distinct from general usage frequency in criterion (c).
Annex VI (f) requires consideration of the share of persons with disabilities in the population using the product or service. Market surveillance authorities will check all six Annex VI criteria.
⚠ Annex VI implicitly requires you to identify the least burdensome path to accessibility before claiming the full cost is disproportionate. Enforcement bodies can reject a claim if a less costly compliant alternative existed and was not explored.
Article 13(2) requires that when a disproportionate burden exemption is invoked, an interim accessible means of access must be provided to users. This must also be documented in your public Accessibility Statement.
This assessment must be available for inspection on request to market surveillance authorities. Include the contact to which such requests should be directed.
Article 14(4): assessment must be renewed on significant product/service change, not only on the 5-year cycle. Document your triggers now so teams know when to reassess.
Assessment Result
of annual turnover
Enter compliance cost to see assessment.
Required for Article 14(4) documentation
How to claim burden
- 1.
Document: Use the export tool to generate your formal Annex VI assessment document.
- 2.
Notify: File the assessment with your national market surveillance authority (Article 14.7). You cannot rely on the burden exemption until this is done.
- 3.
Publish: Document the claim in your public Accessibility Statement (Article 14.4).
- 4.
Renew: This assessment must be reviewed every time your product or service significantly changes, and at least every 5 years (Article 14, recital 73). Set a calendar reminder now.
Renewal obligation — Article 14(4)
A disproportionate burden assessment is not permanent. It must be reassessed whenever the product or service significantly changes, and at a minimum every 5 years. Failure to renew may invalidate the exemption claim.
Annex VI — Full text of criteria
"Economic operators shall take into account the following criteria: (a) the ratio of the net cost of compliance with accessibility requirements to the overall operating costs; (b) the estimated costs and benefits for the economic operator in relation to the estimated benefit for persons with disabilities, taking into account the frequency and duration of use of the specific product or service; (c) the frequency and duration of use of the product or service; (d) the availability of accessible alternatives to cover the same need; (e) the frequency and duration of use of the product or service by persons with disabilities; (f) the share of persons with disabilities in the overall population using the product or service."
Directive 2019/882, Annex VI
Export as evidence
Add organisation name above to enable export
Every export includes a legal-evidence metadata footer with the audit ID, generation date, tool version, EN 301 549 clauses, and the standard disclaimer. Legal-grade evidence — not legal advice.
Important Legal Disclaimer
This tool is a self-assessment aid only and does not constitute legal advice or a formally certified compliance assessment. Outputs — including reports, scores, checklists, and accessibility statements — are for internal use and should be reviewed by a qualified legal representative or independent accessibility auditor before being relied upon for regulatory, procurement, or public-disclosure purposes. All assessment risk lies with the internal assessor. accessibilityref, its developers, and staff accept zero liability for losses arising from use of or reliance on these outputs. Always verify against official sources: the W3C WCAG 2.2 Recommendation, the European Accessibility Act (Directive 2019/882), and your national enforcement authority.