Correctly populating the EN 301 549 Annex Tables
Issue #111 documents what the European Accessibility Act (EAA) requires in terms of the accessibility of ICT products and services. A requirement on Harmonised Standards that support European Directives is that they have an "Annex Z" that shows how the requirements in the standard support the subset of the essential requirements in the Directive that are withing the overall scope that the standard is required to address. As EN 301 549 supports two Directives, the Web Accessibility Directive (WAD) and the European Accessibility Act (EAA), EN 301 4549 will have an Annexe ZA and an Annex ZB to apply to each Directive (in the above order). These tables must identify which EN 301 549 requirements map to which of the essential requirements of the directive.
In addition to these Annex Zx tables, it is also necessary to have tables that suppliers and monitoring authorities can use to determine whether a product or service meets the requirements of the Directive. For the WAD, the Annex ZA tables be used equally well for both purposes. Due to the number and complexity of the essential requirements of the EAA, it is impossible to have both functions performed by a single table. This is doubly so because the EAA is structured according to product and service categories, which "the design principles that apply to the document" document makes clear is not a workable approach to determining which accessibility requirements apply to which specific item of ICT.
So, for EAA compliance, it will be necessary to have a separate table (or possibly tables) that suppliers and monitoring authorities can use to check whether an item of ICT meets the EAA accessibility requirements. This/these tables can be included in a revised Annex A, which will also provide links to the Annex ZA tables that those trying to determine compliance with the WAD can use.
A crucial point is that no accessibility requirements can be included in this new EAA table(s) unless they also appear in the Annex ZB tables, as meeting such requirements is not a requirement needed for EAA compliance. The Annex ZB table is likely to refer to groups of requirements (e.g. clause 6.2.1 (RTT provision) rather than the several requirements (such as 6.2.1.1 RTT communication) that were members of that group of requirements. Including each of the members of these groups of requirements in the Annex A EAA table is both acceptable and necessary. I would be surprised if there are any/many requirements that are not relevant to the EAA!
This Master Table shows current proposals about which requirements should appear in selected tables in the EN 301 549 annexes. This table will be continuously updated during the design and populating of the tables and should be useful in tracking whether there are omissions from either the Annex A or the Annex ZB tables.