The European Accessibility Act: A Complete Guide for Irish Businesses

The European Accessibility Act (EAA) became enforceable in Ireland on 28 June 2025. If your business provides one of the services it covers to consumers, such as selling or taking bookings online, consumer banking or passenger transport, the websites and apps you use to provide that service must meet accessibility standards. Microenterprises providing services are exempt, and public bodies come under separate rules. Having a website is not, on its own, what brings a business into scope.

This guide explains what the EAA actually requires, who it applies to, what the penalties look like, and the practical steps you need to take to get compliant. It is written for Irish business owners and managers - not for lawyers or accessibility specialists.

1. What is the European Accessibility Act?

The European Accessibility Act is an EU Directive (2019/882) that establishes common accessibility requirements across the EU for digital products and services. Its purpose is to ensure that people with disabilities - an estimated 87 million people in the European Union - have equal access to digital services and the broader digital economy.

In Ireland, the EAA was transposed into national law through S.I. No. 636 of 2023 - the Accessibility of Products and Services Regulations 2023. These regulations give the EAA legal force in Ireland, including the criminal penalties for non-compliance.

The enforcement date was 28 June 2025. Businesses whose in-scope products and services do not meet the accessibility requirements are already in breach of Irish law.

What digital products and services does it cover?

The EAA covers a defined list of products and services. For services, the websites and mobile apps used to provide them are in scope:

• E-commerce stores and online booking systems
• Online banking and financial services
• Telecommunications websites and customer portals
• Transport information services and ticketing
• Streaming services and digital media platforms
• E-books and e-reading software
• Self-service terminals (ATMs, ticketing kiosks, check-in machines)

If your business provides any of the above to consumers in Ireland or elsewhere in the EU, and is not a microenterprise providing services, the EAA applies to those services.

2. Who does the EAA apply to?

One of the most common misconceptions about the EAA is that it only targets large corporations or public sector bodies. This is wrong.

The EAA applies to businesses that provide in-scope products or services to consumers in the EU via a digital channel: e-commerce, consumer banking, passenger transport, e-books and dedicated software, electronic communications and audiovisual media access. There is no turnover threshold for those businesses, with one exception: Regulation 5(4) of S.I. No. 636 of 2023 exempts microenterprises providing services (fewer than 10 employees and turnover of €2 million or less). See the myths section below for the detail.

What that looks like in practice

In everyday terms, these are the kinds of Irish business most likely to be in scope (if they are over the microenterprise threshold):

• Consumer banking - Online banking, credit union member areas and loan applications, and payment services
• E-commerce - Any website that lets consumers buy goods or services online, including click-and-collect and online ordering
• Transport - Websites and apps providing passenger transport information, ticketing, or real-time travel updates
• Telecommunications - Provider websites, customer portals, and account management tools
• Hospitality and tourism - Hotel booking engines and online ticket or tour sales, which count as e-commerce. A page that only gives visitor information, with no booking or payment, is not in itself a covered service

Public sector bodies are not covered by the EAA for their own websites. They have had their own rules since 2020: S.I. No. 358 of 2020, the Irish rules for the EU Web Accessibility Directive, which require their sites to meet the accessibility standard and publish an accessibility statement, monitored by the National Disability Authority.

What about B2B businesses?

The EAA is about services provided to consumers. If your business sells only to other businesses, the covered-service obligations generally do not apply to that activity. If you sell to both, the consumer-facing services are the ones that count. Where you are unsure, take advice on your specific situation.

What if my business is based outside Ireland?

If your business is headquartered outside Ireland but provides services to Irish consumers, the EAA still applies to those services. EU consumer protection legislation follows the consumer's location, not the business's place of establishment. A US, UK, or non-EU business serving Irish customers online must meet the same accessibility requirements as a business registered in Dublin.

3. What does EAA compliance actually mean?

The EAA sets accessibility requirements in broad terms and references technical standards for the detail. For websites and mobile apps, the relevant technical standard is EN 301 549. Its latest version (V4.1.1, published September 2026) adopts WCAG 2.2 Level AA as the benchmark for web content. Until that version is cited in the EU Official Journal, the formally cited version still points to WCAG 2.1 AA; auditing to WCAG 2.2 AA covers both.

Understanding WCAG 2.2 AA

WCAG - the Web Content Accessibility Guidelines - is the internationally recognised standard for web accessibility, published by the W3C. Version 2.2 at Level AA is the benchmark in the latest EN 301 549, the standard the EAA relies on.

WCAG 2.2 AA is built on four core principles. Your website must be:

• Perceivable - Information must be presented in ways all users can perceive. Images need descriptive alt text. Videos need captions. Text must have sufficient colour contrast so that users with low vision can read it. Content must not rely solely on colour to convey meaning.
• Operable - All functionality must work without a mouse. Menus, forms, and interactive elements must be navigable by keyboard. Touch targets must be large enough to tap accurately. Time limits must be adjustable. Flashing content that could trigger seizures must be avoided.
• Understandable - Content must be readable and predictable. Forms must have clear labels, useful instructions, and helpful error messages that tell users what went wrong and how to fix it. The language of the page must be correctly set in the HTML.
• Robust - Your site's code must be structured so that assistive technologies - screen readers, voice control software, switch access, braille displays - can reliably interpret it. This means correct HTML semantics, ARIA attributes where needed, and avoiding JavaScript patterns that break accessibility.

The most common failures on Irish SME websites

Based on accessibility audits of Irish business websites, the issues we encounter most frequently are:

• Text and background colour combinations that fail minimum contrast ratios - particularly on grey-on-white body text, teal-on-navy footers, and light-coloured call-to-action buttons
• Images missing descriptive alt text, or with alt text that simply repeats the filename ("image001.jpg")
• Contact forms and booking forms with unlabelled input fields - a screen reader user cannot tell what to type in a field with no accessible label
• Navigation menus that collapse or fail entirely when a mouse is not available
• Cookie consent banners and pop-ups that cannot be dismissed using a keyboard
• Heading structures that skip levels or use heading tags for visual styling rather than document structure
• No published accessibility statement

None of these are obscure technical edge cases. They are mainstream failures that affect real users with real disabilities on a daily basis.

The accessibility statement requirement

The EAA requires in-scope service providers to publish information explaining how their service meets the accessibility requirements (Schedule 3 of S.I. No. 636 of 2023). Most do this as an accessibility statement on their website, which public bodies are separately required to publish under S.I. No. 358 of 2020. A good statement should:

• Describe the extent to which your site meets WCAG 2.2 AA
• List any known accessibility issues and your timeline for fixing them
• Provide a mechanism for users to report accessibility problems
• Explain how your business will respond to accessibility complaints

For in-scope services and public bodies, publishing this information is a legal requirement - but it is not a substitute for actually fixing accessibility issues. Publishing a statement while your site remains inaccessible is not a compliant position and will not protect you from enforcement action.

4. The penalties for non-compliance

This is where many Irish business owners are surprised. For businesses the Act covers, non-compliance is not a civil regulatory matter subject to a fine - it is a criminal offence under Irish law, with penalties set out in Regulation 32 of S.I. No. 636 of 2023.

Personal liability for directors and managers

Regulation 33 of S.I. No. 636 of 2023 provides for personal criminal liability. Where an offence by a company is proven to have been committed with the consent, connivance or approval of, or to be attributable to the wilful neglect of, a director, manager, company secretary or other officer, that person commits an offence as well as the company, and can be proceeded against and punished personally.

This means that for an in-scope business, a director's exposure is not always limited by the company structure. Regulation 34 gives a defence where the person charged proves they exercised due diligence and took all reasonable precautions to avoid the offence, which is why a documented audit and remediation record matters.

Six enforcement authorities

Ireland has designated six bodies that can bring prosecutions under S.I. No. 636 of 2023 (Regulation 35), each for its own sector: the Competition and Consumer Protection Commission, the Commission for Communications Regulation, the Central Bank of Ireland, the National Transport Authority, the Irish Aviation Authority and Coimisiún na Meán.

Consumer and disability organisation complaints

Enforcement does not depend solely on a regulator choosing to investigate. Individuals with disabilities and disability advocacy organisations can bring complaints directly. This creates a parallel route to enforcement that is not subject to regulator prioritisation decisions.

5. Common myths about EAA compliance

"We're too small for this to apply"

Size does matter here, contrary to a good deal of the marketing around the Act. Regulation 5(4) of S.I. No. 636 of 2023 exempts microenterprises providing services, meaning fewer than 10 employees and an annual turnover or balance sheet total of €2 million or less, and the CCPC's guidance for microenterprises states that the requirements and obligations do not apply to them. Two caveats are worth knowing. The exemption covers services, not products, so a microenterprise placing a covered product on the market still has obligations. And it is a threshold rather than a permanent status: hire past ten people, or grow turnover beyond €2 million, and the obligations begin. A five-person firm with a brochure website is outside the Act. That is not the same as being outside equality law, and an inaccessible site still turns customers away.

"We've installed an accessibility overlay widget - we're covered"

Overlay widgets are third-party tools that sit on top of a website and claim to automatically fix accessibility issues for users. They do not make your site compliant with the EAA. EU and Irish regulators have been clear that automated overlays do not satisfy the legal requirements. Several major overlay products have been found to actively make sites harder to use for screen reader users, and they have been the subject of legal challenges in the US and Europe. An overlay masks problems visually while leaving the underlying code failures in place. It is not a substitute for proper remediation.

"We have an accessibility statement - that's enough"

For in-scope services, publishing accessibility information is a legal requirement, but it is one component of compliance, not the whole of it. A statement that says "our site has known accessibility issues that we are working to fix" while no actual fixing is happening is not a compliant position. Regulators and courts will look at the substance of what you have done, not just what you have published.

"We'll wait until we get a complaint before worrying about it"

Criminal law does not require a complaint before an offence exists. Once the enforcement date passed on 28 June 2025, non-compliant in-scope services were already in breach. A complaint is one mechanism that might trigger an investigation, but it is not the only one, and it is not a trigger for the obligation itself. By the time a complaint arrives, the offence has already been committed and the evidence of non-compliance is on record.

6. What you need to do - the practical steps

Getting compliant is achievable for most Irish SMEs. The typical process has four stages:

1. Get a proper accessibility audit

   You cannot fix what you have not measured. A proper accessibility audit identifies every WCAG 2.2 AA failure on your site, rates each issue by severity (Critical, Major, Moderate or Advisory), and explains exactly what needs to change. A free homepage check is a useful starting point - it identifies obvious failures on your most important page and gives you a realistic sense of the scope of work required. A full paid audit covers all your key pages and provides the Developer Fix Guide your web team needs to act immediately.

2. Implement the fixes

   Most accessibility failures are code-level changes that any competent web developer can implement from a clear brief. Common fixes include: updating CSS colour values to meet contrast ratios; adding alt attributes to images; adding <label> elements to form inputs; adding aria-label attributes to icon buttons; correcting heading hierarchy; and ensuring keyboard focus is visible on all interactive elements. A Developer Fix Guide translates each audit finding into a specific code-level instruction, removing ambiguity and keeping developer time low.

3. Publish an accessibility statement

   Once your developer has implemented the fixes, publish an accessibility statement on your site. It should describe your compliance position, name any remaining known issues with your remediation timeline, and provide a contact method for accessibility-related queries. For in-scope services and public bodies it is a legal requirement, not an optional extra.

4. Monitor and maintain

   Accessibility compliance is not a one-time exercise. Websites change as content is added, templates are updated, and new features are deployed. New content can introduce new issues. A lightweight annual re-audit catches problems early, before they accumulate or become enforcement risks. Many clients run a full audit to achieve compliance and then schedule an annual check to stay there.

What about user journey testing?

Static page audits identify the majority of accessibility failures, but interactive flows - checkout processes, booking forms, login journeys, account management - can have failures that only appear when a user is actually completing the journey step by step. If your site has a checkout, reservation system, or member login, user journey testing is strongly recommended alongside your standard page audit. Issues like keyboard traps, missing focus management after form submissions, and inaccessible error announcements are only detectable in live interaction. Our journey testing also includes a first-time user journey walkthrough: the same flow, walked as a visitor who has never seen the site, to find the points where an ordinary customer would get stuck. Those findings are usability advice and are kept separate from the legal requirements.

7. Cost and timelines

For most Irish SME websites, the end-to-end compliance process is achievable within 4–8 weeks from first audit to confirmed compliance. Here is how the timeline typically breaks down:

• Accessibility audit: 1–7 business days depending on site size (homepage check in 1 day; full site audit in 3–7 days)
• Developer remediation: 1–3 weeks of developer time for typical SME sites, depending on the number and severity of issues found
• Re-scan to confirm compliance: 1–3 business days once fixes are deployed

The cost of a full site audit for a compact Irish SME website starts at €195 - a fixed, one-time fee with no retainer and no hidden extras. A free homepage check is available with no commitment, delivered within one business day.

By comparison, for a business the Act covers: a criminal fine of up to €60,000 on indictment, legal costs defending an enforcement action, and the reputational damage of a public accessibility complaint dwarf the cost of getting compliant now.

There is also a positive commercial case. Accessible websites rank better in search engines (Google's crawlers benefit from the same semantic HTML structure that assistive technologies rely on). They convert better on mobile (proper tap target sizes and form labels improve the experience for all users). And they reduce the risk of losing customers who encounter barriers - more than one in five people in Ireland reported a disability in the 2022 census.

8. Frequently asked questions