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 Directive, Article 5, Disproportionate burden
- Directive (EU) 2019/882, European Accessibility Act, Article 4, Accessibility requirements
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- Directive (EU) 2016/2102, Public Sector Accessibility DirectiveArticle 5, Disproportionate burden
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1. Member States shall ensure that public sector bodies apply the accessibility requirements set out in Article 4 to the extent that those requirements do not impose a disproportionate burden on the public sector bodies for the purposes of that Article. 2. In order to assess the extent to which compliance with the accessibility requirements set out in Article 4 imposes a disproportionate burden, Member States shall ensure that the public sector body concerned takes account of relevant circumstances, including the following: (a) the size, resources and nature of the public sector body concerned; and (b) the estimated costs and benefits for the public sector body concerned in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the specific website or mobile application. 3. Without prejudice to paragraph 1 of this Article, the public sector body concerned shall perform the initial assessment of the extent to which compliance with the accessibility requirements set out in Article 4 imposes a disproportionate burden. 4. Where a public sector body avails itself of the derogation provided for in paragraph 1 of this Article for a specific website or mobile application after conducting an assessment as referred to in paragraph 2 of this Article, it shall explain, in the accessibility statement referred to in Article 7, the parts of the accessibility requirements that could not be complied with and shall, where appropriate, provide accessible alternatives.
Retrieved 2026-04-30View on EUR-Lex ↗ - Directive (EU) 2019/882, European Accessibility ActArticle 4, Accessibility requirements
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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. 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. 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. 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. 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. 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. 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. 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. 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.
Retrieved 2026-04-29View on EUR-Lex ↗
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
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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.