EAA electronic communications and 112

In brief

Electronic communications services are in the scope of the European Accessibility Act (Article 2(2)(a)), together with the consumer terminal equipment used for them (Article 2(1)(c)). Annex I adds requirements for real-time text, total conversation and emergency communications.

The Directive also applies to answering emergency communications to the single European emergency number 112 (Article 2(3)).

Which services are covered?

Article 2(2)(a) covers electronic communications services, with the exception of transmission services used for the provision of machine-to-machine services.

Requirements for communications services (Section IV, point A)

• Provide real-time text in addition to voice.
• Provide total conversation where video is offered together with voice.
• Make sure emergency communications using voice, text (including real-time text) and, where available, video are synchronised and passed to the most appropriate public-safety answering point (PSAP).

Check the exact wording of Annex I before you cite it.

Terminal equipment

For consumer terminal equipment with interactive computing capability used for electronic communications, Annex I, Section I includes these requirements:

• support real-time text and high-fidelity audio, where the device handles text as well as voice;
• support total conversation, where the device has video alongside text and voice;
• provide effective wireless coupling with hearing technologies;
• avoid interference with assistive devices.

Calls to 112 (Section V)

Section V covers the answering of calls to 112 by the most appropriate PSAP. Answering must include functions, practices, policies and procedures that address the needs of persons with disabilities. Calls must be answered appropriately, in the way suited to each Member State's national emergency system, using the same means of communication as received: synchronised voice and text (including real-time text), or, where video is provided, synchronised voice, text and video as total conversation.

Article 4(8) lets Member States defer the application of Section V until 28 June 2027. Check the national position.

Who this affects

Mainly telecom operators, communication app providers, device makers and emergency service organisations. If you run a website for a communications provider, the general requirements for websites and apps also apply. See e-commerce requirements for a summary of Section III.

What to do

• Check whether you are in scope. Compare your service with Article 2(2)(a) and the machine-to-machine exception.
• Check real-time text and total conversation. Where you offer voice, check text; where you offer video, check total conversation.
• Check the emergency route. Synchronised media must reach the most appropriate PSAP.
• Check device features. Hearing technology coupling and no interference with assistive devices.
• Check national deferral. See whether your Member State uses the 2027 date for Section V.

Common mistakes

• Voice only. Section IV asks for real-time text alongside voice.
• Video without total conversation. Where video is offered with voice, total conversation is required.
• Unsynchronised emergency media. Voice, text and video must be synchronised for emergency communications.
• Ignoring the device. Devices have their own requirements under Section I.
• Assuming 112 applies the same everywhere. Section V can be deferred by Member States until 28 June 2027.

Sources

• Directive (EU) 2019/882, European Accessibility Act (EUR-Lex), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.