Require accessibility statements
M/587, Preamble (13) seems to require that EN 301 549 shall contain a requirement that ICT services are accompanied with an accessibility statement.
This is the preamble (13):
(13) Harmonised standard EN 301 549:2021 has been drafted in support of Directive (EU)
2016/2102 on the basis of Commission Implementing Decision C(2017) 25822
to the ESOs in the field of accessibility of websites and mobile applications of public sector
bodies. The harmonised standard needs to be revised and completed to take into
account essential accessibility requirements set out in Directive (EU) 2019/882 and the
scope of products and services, covered by Directive (EU) 2019/882. When revising
this harmonised standard, for the purpose of Directive (EU) 2019/882, the accessibility
levels already established in EN 301 549 should be maintained as a minimum and
revisions to that harmonised standards for the purposes of Directive (EU) 2016/2102
should be done on the basis of this request.
**To ensure information to consumers about accessibility requirements to services, in line with Annex I section III (c) to Directive 2019/882, the revised and new harmonised standards should include accessibility statements similar to those in Article 7 of Directive 2016/2102. **
Even if the preamble says that the HS itself should include the accessibility statement, I assume that it is meant that the HS should include requirements on the services to provide accessibility statements.
We need to decide where this requirement shall be placed and what it shall contain. An opportunity for the RTT interoperability test clause is that the requirements on the accessibility statement is that it shall include information on which interoperability protocols for RTT the service implements. Then that test can be to look for that info in the accessibility statement.