Functional Performance Criteria.

The Functional Performance Criteria (FPC) are a crucial part of Annex I of the European Accessibility Act. They define outcomes that products and services must achieve to be considered accessible to people with disabilities.

These criteria ensure that regardless of specific disability, all users can effectively interact with products and services through at least one accessible method for each function.

The FPC serve as a framework when specific technical requirements don't fully address all product or service features. They help organizations understand the goals of accessibility even when detailed technical specifications aren't available.

Products and services must be operable and usable by people with the following visual disabilities:

• Without Vision

  Products and services must provide at least one mode of operation that doesn't require vision. This includes:

  • Text-to-speech for textual content
  • Tactile controls and feedback
  • Audio descriptions for visual content
  • Compatibility with screen readers
  • Alternative formats such as braille or audio
• With Limited Vision

  Products and services must provide at least one mode of operation that accommodates users with limited vision. This includes:

  • Magnification without loss of content or functionality
  • Adjustable font sizes
  • Flexible spacing and formatting
  • Adjustable brightness and contrast
  • Alternative color schemes
• Without Color Perception

  Products and services must provide at least one mode of operation that doesn't require user color perception. This includes:

  • Never using color alone to convey information
  • Providing text alternatives for color-coded information
  • Using patterns or shapes in addition to color
  • Ensuring adequate contrast between text and background
  • Allowing user customization of color schemes

Products and services must be operable and usable by people with the following hearing disabilities:

• Without Hearing

  Products and services must provide at least one mode of operation that doesn't require hearing. This includes:

  • Visual or tactile alternatives to audio signals
  • Captions for audio content
  • Sign language interpretation for spoken content
  • Text-based communication alternatives
  • Visual notifications for alerts and warnings
• With Limited Hearing

  Products and services must provide at least one mode of operation that accommodates users with limited hearing abilities. This includes:

  • Volume controls with amplification beyond standard levels
  • Noise reduction for improved audio clarity
  • Frequency control to enhance speech comprehension
  • Compatibility with hearing aids and cochlear implants
  • Options to separate foreground speech from background sounds
• Without Vocal Capability

  Products and services must provide at least one mode of operation that doesn't require the user to generate vocal sounds. This includes:

  • Text or image-based inputs as alternatives to voice commands
  • Real-time text communication options
  • Support for message composition using symbols or prewritten text
  • Alternative ways to make selections and give commands
  • Support for sign language input via camera where applicable

Products and services must be operable and usable by people with the following physical limitations:

• With Limited Manipulation or Strength

  Products and services must provide at least one mode of operation that can be used by people with limited manual dexterity, reach, or strength. This includes:

  • Support for alternative input devices (switch controls, eye tracking, etc.)
  • Voice control options for navigation and interaction
  • Touch-free operation options
  • Sequential key presses as alternatives to simultaneous key combinations
  • Adjustable timing for interactions
  • Large, easy-to-press controls requiring minimal force
• With Limited Reach

  Products and services must accommodate users with limited reach and those who might use assistive devices. This includes:

  • Placing interactive elements within accessible reach ranges
  • Allowing operation from multiple positions
  • Providing remote control options where applicable
  • Support for voice or proximity activation
  • Ensuring compatibility with assistive reaching tools
• With Photosensitive Seizures

  Products and services must provide at least one mode of operation that minimizes the potential for triggering photosensitive seizures. This includes:

  • Avoiding flashing content that exceeds safe thresholds
  • Providing options to disable animations and flashing elements
  • Allowing user control over visual stimuli
  • Warning users about content that might trigger seizures
  • Offering alternative non-visual ways to access the same functionality

Products and services must be operable and usable by people with cognitive limitations:

• With Limited Cognitive Ability

  Products and services must provide features that make them easier to use for people with various cognitive, language, and learning disabilities. This includes:

  • Predictable and consistent patterns of interaction
  • Clear, simple language and instructions
  • Step-by-step guidance for complex processes
  • Multiple ways to access and understand content (text, audio, video)
  • Reduced complexity and cognitive load
  • Error prevention and simple error correction
  • Minimal distractions
  • Support for extended time to complete tasks
  • Memory aids and reminders
  • Options to customize displays to reduce cognitive overload

These requirements help make products and services more accessible to people with conditions such as intellectual disabilities, autism, dyslexia, ADHD, and memory impairments.

The EAA includes a specific functional performance criterion related to privacy:

• Privacy When Using Accessibility Features

  Products and services must provide at least one mode of operation that maintains privacy when users are utilizing accessibility features. This means:

  • Accessibility features should not compromise user privacy
  • Personal headsets must be supported for private audio output
  • Screen reader output should be available through headphones
  • Visual information should be protected from onlookers when needed
  • Authentication and identification methods must be accessible without compromising security

This criterion recognizes that people using accessibility features should be able to maintain the same level of privacy as other users, particularly in public settings or when dealing with sensitive information.

The functional performance criteria should be used as follows:

• As complementary requirements: If the specific technical requirements in other sections of the EAA don't adequately cover certain aspects of accessibility, the functional performance criteria should be used to address those gaps.
• As guiding principles: When designing products and services, these criteria provide a user-centered perspective on accessibility goals, focusing on the outcomes for people with disabilities rather than just technical specifications.
• For innovative solutions: When new technologies emerge that aren't explicitly covered by existing technical requirements, these criteria can guide the implementation of accessible features.
• For testing and validation: These criteria can be used to validate that accessibility features truly meet the needs of users with different disabilities.

To meet these criteria, manufacturers and service providers should:

• Consider the full range of user abilities in their design process
• Incorporate multiple modes of operation and interaction
• Test with users who have different disabilities
• Document how their products or services meet these performance criteria
• Update designs as new accessibility technologies and approaches become available