ZIMI – Assessment of Non-Feasibility of Accessibility Adjustments
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ZIMI – Assessment of Non-Feasibility of Accessibility Adjustments

Main entrance of the National and Natural History Museum of Slovenia - Staircase at the main entrance of the National and Natural History Museum of Slovenia, where accessibility adjustments cannot be implemented due to heritage protection regimes.
Tilen Jurca

There is only one month left to prepare the Assessment of Non-Feasibility of Accessibility Adjustments.

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The Assessment of Non-Feasibility of Accessibility Adjustments must be prepared by 13 July 2026 for every publicly accessible building where specific required accessibility measures for persons with disabilities have not been implemented for justified reasons, so that it is available, together with supporting documentation, to the building inspectorate if it visits the site.
More about the background of the document can be found here. 

Basic building data
In the first part of the form, basic identification data of the building and its owner or manager are provided. Under ZIMI, the manager is obliged and therefore also legally responsible for fulfilling accessibility requirements.
Basic data such as address, cadastral municipality, building number, and classification according to CC-SI can be found in existing GURS documentation or via the e-Prostor portal, where you enter the address and select the correct building on the map. The information window then shows the cadastral municipality (KO) and building number.
In the section “Parts of the building”, the “Actual use of the building part” is provided, which descriptively defines the classification of use (e.g. “museum and library”). Using the Unified Classification of Types of Construction (CC-SI), the corresponding code can then be added, e.g. 12620.

Implemented accessibility measures
Implemented measures represent a smaller part of the form. The purpose is to list adjustments (e.g. accessible parking spaces, ramps, accessible toilets, induction loops, signage, etc.) that have been implemented despite other measures being unfeasible.
This overview demonstrates that the responsible party has already improved accessibility where possible and that the non-feasibility of certain measures does not mean the building cannot be made more accessible overall.

Identified non-feasible adjustment
A repeated table structure must be completed for each individual barrier.
The description must be concrete and specific. Instead of a general statement such as “the main entrance is not accessible”, it is more appropriate to write: “There are three steps at the main entrance to the building, preventing access for wheelchair users.”
The form requires photographs that additionally show the specific barrier or location to which the entry refers, for each non-feasible adjustment.

A reason for non-feasibility is then selected and justified with supporting evidence. The form provides four possible reasons:

  • Technical infeasibility
    Used when the adjustment cannot be objectively implemented due to technical constraints of the building or space. A professional opinion by a licensed architect or civil engineer is required.
  • Deterioration of essential or other building requirements
    Used when the adjustment would compromise structural stability, fire safety, or other requirements under construction legislation. A professional opinion by a licensed architect or civil engineer is also required.
  • Disproportionate burden
    High cost alone is not sufficient. Cost estimates or quotations are required, along with a justification that considers the size, financial capacity, and other circumstances of the entity. A low number of disabled visitors is explicitly not a valid reason for non-compliance.
  • Heritage protection
    Even when a building is under heritage protection regimes, these may be specific and apply only to parts of the building. In cooperation with the Institute for the Protection of Cultural Heritage of Slovenia (ZVKDS), many adjustments may still be feasible. If this is not the case, the form provides guidance for obtaining the necessary supporting documentation from ZVKDS.

It is recommended that attachments are clearly numbered so it is evident which non-feasible adjustment they refer to, and that the justification text explicitly references them.

Equal access to goods and services
ZIMI requires consideration of how users will be ensured access to services even when certain physical adjustments cannot be implemented. Services should be provided at an alternative accessible location or at home, with prior notice and assistance enabled.

This section demonstrates whether the responsible party is actively seeking solutions for equal treatment of persons with disabilities or merely justifying non-implementation of construction measures.
If any uncertainties or questions arise during form completion, you may always contact us for clarification.

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