8 Accessibility
8.1 Introduction
Accessibility of all User-facing components of the EUDI Wallet ecosystem, such as Wallet Units, websites, User authentication methods of PID Providers and Attestation Providers, and registries (see [Section 3.17][317-registrars]), is essential to ensure that these digital tools are inclusive by design and aligned with the applicable European legal and technical frameworks.
Accessibility is not only a matter of legal compliance but also a fundamental condition for equal access, User trust, and widespread adoption across all segments of the population, including persons with disabilities.
For high-level requirements on accessibility, please refer to [Topic 54][topic-54].
For more information, also see the Discussion Paper for Topic Q.
8.2 Legal instruments and standards
The following main legislative instruments and standards apply:
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Directive (EU) 2016/2102 on the accessibility of websites and mobile applications of public sector bodies. This Directive establishes a common framework to harmonise accessibility requirements across Member States, ensuring that digital public services, including mobile applications, are perceivable, operable, understandable, and robust for all Users. In particular, it requires compliance with ETSI EN 301 549 v1.1.2, which defines accessibility requirements for ICT products and services, covering web content, software, mobile applications, hardware interfaces, and documentation.
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Directive (EU) 2019/882, the European Accessibility Act (EAA). This Directive extends accessibility obligations to a wider range of products and services placed on the EU market, including digital services beyond the public sector. It sets essential accessibility requirements for economic operators, including service providers and manufacturers, ensuring that solutions such as Wallet Units are accessible to persons with disabilities throughout their entire lifecycle, from design and development to marketing and after-sales support.
8.3 Wallet Units and other User-facing components
Together, these legal instruments create a coherent legal and normative environment that supports the development of accessible Wallet Units and related components. Compliance with these frameworks is both a regulatory obligation and a driver of innovation, social inclusion, and digital equality.
It is therefore crucial that accessibility is integrated into:
- Technical specifications
- User interface design
- Testing processes
- Procurement criteria
for all elements of the Wallet ecosystem.
Member States and implementing entities should also ensure ongoing monitoring, effective feedback mechanisms, and continuous improvement of accessibility practices. This requires close collaboration with Users, accessibility experts, and organisations representing persons with disabilities, to guarantee that Wallet Units and other User-facing components remain usable, effective, and inclusive for all.