Functional Performance Criteria

Disclaimer

The information in this section should not be taken for legal advice and is intended to be used for information purposes only. The examples provided are not intended to be recommendations, nor is the NDA in the position to provide legally verifiable pathways to comply with the European Accessibility Act.  

Introduction

The European Accessibility Act (Directive 2019/882) sets out a range of accessibility requirements for certain products and services. Most of these are specific and detailed (See Annex 1, Sections 1-6). However, not every situation is covered in those requirements and that’s where the EAA’s Functional Performance Criteria come in (see Annex 1, Section 7). On this page we’ll explain those criteria, detail how they can be used and share examples to help you apply them.

What are the Functional Performance Criteria? 

The Functional Performance Criteria are intended to be used to judge how well your product or service works for a range of users with different disabilities, across eleven categories. When correctly applied, the EAA’s functional performance criteria will enable people to locate, identify, operate and access products and services regardless of physical, cognitive, or sensory abilities. 

How can the Functional Performance Criteria be used?

Whenever the Functional Performance Criteria are used, they need to produce the same or higher degree of accessibility than would be provided by fulfilling the accessibility requirements. The Functional Performance Criteria can never be used to provide lower levels of accessibility than would otherwise be ensured by the EAA.

The functional performance criteria can only be applied in the following ways: 

• Where specific functions of your product or service are not specifically addressed by a particular accessibility requirement in Annex 1, Section 1-6, but are still part of a product or service covered by the EAA, those unmentioned functions still need to satisfy the Functional Performance Criteria.
• Where a company determines that a specific accessibility requirement hinders innovation or they cannot fulfil it in the way that requirements dictate, they may use other technical solutions that satisfy the Functional Performance Criteria to achieve the required result.  

Breaking Down the Functional Performance Criteria 

The following is a list of the criteria that products and services covered by the EAA must meet, with corresponding examples. Each criterion indicates that the production of a product or provision of a service should provide at least one mode of operation that enables: 

1. Usage without vision

‘Where the product or service provides visual modes of operation, it shall provide at least one mode of operation that does not require vision.’ 

• Audio and tactile user interfaces may contribute towards satisfying this criterion. 

Example of usage without vision

A remote that is used to connect with a smart TV provides tactile buttons that indicate each button’s use could support this criterion. For example, a raised plus and a minus sign on buttons to indicate how to raise and lower the volume.

2. Usage with limited vision

‘Where the product or service provides visual modes of operation, it shall provide at least one mode of operation that enables users to operate the product with limited vision.’

• Magnification, reduction of required field of vision, and control of contrast, brightness, and intensity can contribute towards meeting this criterion.
• Where significant features of the user interface are dependent on depth perception, adding other ways of telling the features apart can contribute towards meeting this criterion. 

Example of usage with limited vision

A touch screen payment terminal that includes an easily distinguishable button (large, high contrast, findable) to adjust magnification, brightness, and contrast so that the user can use the terminal independently could support this criterion. 

3. Usage without perception of colour 

‘Where the product or service provides visual modes of operation, it shall provide at least one mode of operation that does not require user perception of colour.’

• Where significant features of the user interface are colour-coded, the provision of additional methods of distinguishing between the features may contribute towards meeting this criterion.

Example of usage without perception of colour

Consider a departures board at the airport that distinguishes imminent upcoming departures from later departures by colour. When departures are within 10 minutes of departing, the destination turns red. One way that the departures board could support this criterion is if the change in colour is accompanied by additional text that says, ‘go to gate’. This could provide one way to use it without having to perceive colour.   

4. Usage without hearing 

‘Where the product or service provides auditory modes of operation, it shall provide at least one mode of operation that does not require hearing.’ 

• Visual and tactile user interfaces, including those based on sign language, may contribute towards meeting this criterion.

Example of usage without hearing

A mobile phone that includes the option of a flashing light or vibration instead of an aural ringtone for an incoming message to allow for usage without hearing could support this criterion. 

5. Usage with limited hearing 

‘Where the product or service provides auditory modes of operation it shall provide at least one mode of operation with enhanced audio features that enables users with limited hearing to operate the product.’ 

• Enhancement of the audio clarity, reduction of background noise, providing an option to use the device using a single ear with compatibility for either ear, adjustment of balance of both audio channels, increased range of volume and greater volume in the higher frequency range can all contribute towards meeting this criterion.

Example of usage with limited hearing

A mobile phone which allows the user to tailor the audio experience to meet their needs by facilitating adjustment of audio balance, frequency equalisation, and noise suppression could support this criterion.

6. Usage without vocal capability 

‘Where the product or service requires vocal input from users, it shall provide at least one mode of operation that does not require vocal input. Vocal input includes any orally generated sounds like speech, whistles or clicks.’ 

• Keyboard, pen, or touch user interfaces may contribute towards meeting this criterion.

Example of usage without vocal capability

A consumer banking service that requires a user to call a support line to verify their identity would need to provide an alternative to voice verification, such as inputting a pin or password via keypad could support this criterion. 

7. Usage with limited manipulation or strength 

‘Where the product or service requires manual actions, it shall provide at least one mode of operation that enables users to make use of the product through alternative actions not requiring fine motor control and manipulation, hand strength, or operation of more than one control at a time.’ 

• Examples of operations that users may not be able to perform include those that require fine motor control, gestures where the direction of the gesture is important, pinching, twisting of the wrist, tight grasping, or simultaneous manual actions.
• One handed operation, sequential key entry, and speech user interfaces may contribute towards meeting this criterion.  
• Some users have limited hand strength and may not be able to achieve the level of strength to perform an operation. Alternative user interface solutions that do not require hand strength may contribute towards meeting this criterion. 

Example of usage with limited manipulation of strength

Consider how turning a phone on and off or signing into a laptop often requires the simultaneous pressing of buttons, which requires grip strength and control of your digits. Providing an operation where a simple swiping gesture can complete the task could support this criterion.

8. Usage with limited reach 

‘The operational elements of products shall be within the reach of all users. Where the product or service provides a manual mode of operation, it shall provide at least one mode of operation that is operable with limited reach and limited strength.’

• Considering the needs of wheelchair users and the needs of a range of user statures in the placing of operational elements of the user interface may contribute towards meeting this criterion.

Example of usage with limited reach 

A touch screen, self-service, payment terminal at a fast-food restaurant that provides a feature for users to adjust the presentation of the menu selection to the lower half of the screen could support this criterion. 

9. Minimising the risk of triggering photosensitive seizures 

‘Where the product provides visual modes of operation, it shall avoid modes of operation that trigger photosensitive seizures.’ 

• Limiting the area and number of flashes per second may contribute towards meeting this criterion
• Human beings are more sensitive to red flashing than to other colours. This should be considered in the design of the product to avoid triggering photosensitive seizures.

Example of minimising the risk of triggering photosensitive seizures

To support this criterion, a  product that provides flashing lights to indicate low battery could provide a mode that allows the user to turn off the flashing lights and opt for a different warning mode (such as a sound indicating low battery). 

10. Usage with limited cognition 

‘The product or service shall provide at least one mode of operation incorporating features that make it simpler and easier to use.’ 

• The product or service must provide features that makes it simpler and easier to understand, operate, and use.
• Adjustable timings, error indication and suggestion, and a logical focus order are examples of design features that may contribute towards meeting this criterion.
• Providing an audio output of the text is an example of providing support for people with limited reading abilities
• Providing spelling aid and word prediction of the text is an example of providing support for people with limited writing abilities.
• Interaction with content can be made easier and less prone to errors by presenting tasks in steps that are easy to follow.
• Information should be simple, clear, and concise. 

Example of usage with limited cognition 

Ensuring instructions accompanying a product are understandable for a diverse range of users, potentially by adding explanatory images to guide the user through key functions could support this criterion.

11. Privacy

‘Where the product or service incorporates features that are provided for accessibility, it shall provide at least one mode of operation that maintains privacy when using those features that are provided for accessibility.’ 
Some examples of design features that may contribute towards meeting this criterion: 

• enabling the connection of personal headsets for private listening,
• not providing an audio description of words or characters being masked to hide sensitive text or passwords
• enabling user control of legal, financial, and personal data

Example of privacy

An ATM that has capacity for text to speech, alongside a tactile indicator on the terminal to indicate where a headphone jack is located to allow for users to plug in their headphones to use the ATM privately could support this criterion. 

Benefits of implementing the Functional Performance Criteria

It is important to consider that many people have more than one disability. This means that combinations of the criteria should be addressed in consultation with users who have multiple disabilities.

Implementing multiple modes of functioning across these 11 categories will positively impact many people, including older persons, pregnant people, and people with a range of differences in their characteristics, capabilities, needs, and preferences.

The functional performance criteria can also address the needs of those impacted by a variety of situational or environmental factors. For example, fulfilling the functional performance criterion to provide for use  with limited manipulation or strength can benefit someone who is using your product while their hands are full, while they are pushing a pram, or carrying a child. Designing for one less common human characteristic often benefits many. 

For example, fulfilling the functional performance criteria can allow for neurodiverse users to adjust the mode of operation to address their specific sensory needs so that they may comfortably use a product. 

Implementing the Functional Performance Criteria can be aided by applying the seven principles of Universal Design (UD). To learn more about UD, visit our webpage on the Universal Design Principles.