European Accessibility Act (EAA) in Ireland – All the Key Details

Because the European Accessibility Act (EAA) is transposed into national law by each EU member state, the exact rules can vary slightly from country to country. If you’re a business operating in Ireland and working on EAA compliance, we’re here to help you understand what’s required.

In this post, we break down everything you need to know about the European Accessibility Act in Ireland – who needs to comply, key exemptions, deadlines, penalties, and the steps you need to take to stay compliant. By the end, you’ll have a clear, practical understanding of what’s expected.

How Is the EAA Implemented in Ireland?

In Ireland, the EAA is transposed into Irish law through Statutory Instrument No. 636 of 2023. This regulation outlines accessibility requirements for digital products and services and sets out penalties for businesses that fail to comply.

Who Needs to Comply with the EAA in Ireland?

Under S.I. No. 636 of 2023, the EAA applies to private businesses that offer certain products and services to consumers in Ireland. This includes both manufacturers and service providers.

If your company places these items on the market or provides them to the public, you are responsible for meeting accessibility requirements.

Covered products include:

• Computers and operating systems
• Smartphones
• Payment terminals
• Self-service terminals (e.g., ATMs, check-in machines)
• E-readers

Covered services include:

• E-commerce platforms and online marketplaces
• Banking and financial services (e.g., online banking, ATMs)
• E-books and dedicated reading software
• Electronic communications (e.g., telecom, 112 emergency services)
• Passenger transport services (websites, mobile apps, ticketing)

To fall under the law, the product or service must be intended for consumer use; business-to-business (B2B) offerings are generally not included.

Regulations 3 & 5, S.I. No. 636/2023

Who and What Is Exempt from the EAA in Ireland?

Ireland’s implementation of the EAA includes several specific exemptions and transitional measures. These are designed to reduce the burden on very small businesses and avoid premature replacement of existing products and systems.

1. Businesses that qualify as microenterprises (services only)
2. Certain types of archived and legacy digital content
3. Cases where compliance would cause a disproportionate burden or fundamental alteration

Let’s now go over them in detail.

1. Microenterprises

Businesses with fewer than 10 employees and annual turnover or balance sheet total of €2 million or less are exempt from accessibility requirements for services. However, this exemption does not apply to products they place on the market.

2. Archived and legacy digital content

Certain older web and app content is exempt from accessibility requirements:

• Pre-recorded time-based media (e.g. videos) published before 28 June 2025
• Office documents published before 28 June 2025
• Online maps (if key information is provided in an accessible format elsewhere)
• Content from third parties not controlled or funded by the provider
• Archived content that will not be updated after 28 June 2025

3. Disproportionate burden or fundamental alteration

A business may be exempt from specific requirements if it can prove that:

• Compliance would cause a disproportionate burden, or
• It would fundamentally alter the nature of the product or service

This exemption requires a documented assessment, must be reviewed at least every five years, and cannot be claimed if the business receives funding to support accessibility improvements.

Regulation 15 & Schedule 4

What Are the Compliance Deadlines?

Ireland follows the EU-wide timeline for the European Accessibility Act, as detailed in S.I. No. 636 of 2023. Here’s what businesses need to know:

28 June 2025

All new products and services placed on the market or provided to consumers from this date must comply with EAA accessibility requirements.
Regulation 3(1), S.I. No. 636/2023

Up to 28 June 2030

Products and services already on the market or provided to consumers before 28 June 2025 may continue to be offered until 28 June 2030 without full compliance. After that, they must meet accessibility requirements.
Regulation 38(1)(a), S.I. No. 636/2023

Up to 20 years from first use, no later than 28 June 2045

Self-service terminals (e.g., ATMs, ticketing or check-in kiosks) installed before 28 June 2025 can remain in operation for their expected lifespan, capped at 20 years.
Regulation 38(2), S.I. No. 636/2023

Who Enforces the EAA in Ireland?

In Ireland, multiple monitoring authorities have been appointed to oversee compliance with the European Accessibility Act (EAA) across different sectors:

Sector	Monitoring Authority
Products (e.g. hardware, self-service terminals)	Competition and Consumer Protection Commission (CCPC)
E-commerce, e-books	CCPC
Electronic communications (e.g. telecoms, 112 emergency services)	Commission for Communications Regulation (ComReg)
Audiovisual media	Coimisiún na Meán
Air travel	Irish Aviation Authority (IAA)
Rail, bus, waterborne transport	National Transport Authority (NTA)
Consumer banking	Central Bank of Ireland

Additionally, the National Disability Authority (NDA) acts as an advisor to these regulators but does not enforce the law directly.

What Are the Penalties for Non-Compliance?

Failing to meet the accessibility requirements is a criminal offence under Irish law. According to Regulation 32 of S.I. No. 636/2023, penalties for businesses include:

• For minor offences (summary offences – Regulation 32(6)(a)):
  • A fine of up to €5,000
  • Or up to 6 months in prison
  • Or both
• For major offences (indictable offences – Regulation 32(6)(b)):
  • A fine of up to €60,000
  • Or up to 18 months in prison
  • Or both

Company directors and managers can also be held personally responsible (under Regulation 33), unless they can prove they took reasonable steps to ensure compliance.

How to Ensure EAA Compliance in Ireland

To ensure EAA compliance in Ireland, businesses must follow S.I. No. 636 of 2023, which transposes the European Accessibility Act into Irish law. Compliance is primarily based on the EN 301 549 accessibility standard, alongside general WCAG 2.1 principles for digital content.

Here’s how to get ready:

1. Identify affected products and services to know what must meet EAA requirements.
2. Conduct an accessibility audit to spot compliance gaps.
3. Create a compliance roadmap to plan and prioritize fixes.
4. Train teams on accessibility standards to build with accessibility in mind.
5. Publish an accessibility statement to show status and collect feedback.
6. Set up ongoing monitoring to catch new issues and stay compliant.

Let’s now look at each step in detail.

Step 1: Identify affected products and services

Check whether your business offers consumer-facing services or tools like websites, mobile apps, e-commerce, online banking, telecom, or self-service kiosks. If so, they must meet the accessibility requirements under Irish law.

Step 2: Conduct an accessibility audit

Audit your digital platforms and interfaces against EN 301 549 and WCAG 2.1 Level AA. Use WebYes to test your website for common accessibility barriers. For hardware and physical products, consult with an accessibility expert.

Step 3: Create a compliance roadmap

Build a clear action plan based on your audit findings. Prioritise critical accessibility issues, assign roles across your team, and ensure you’re on track for the 28 June 2025 compliance deadline.

Step 4: Train teams on accessibility standards

Make sure your developers, designers, product managers, and customer-facing staff understand accessibility principles – especially WCAG, EN 301 549, and Ireland’s EAA-specific rules. Provide regular training and updates to embed accessibility into your company culture.

Step 5: Publish an accessibility statement

Once your services meet the legal requirements, publish an Accessibility Statement. This should clearly state your compliance level and offer users a way to report any remaining accessibility issues.

Step 6: Set up ongoing monitoring

Accessibility isn’t one-and-done. Set up continuous testing using automated tools like WebYes, and schedule periodic manual reviews to ensure your site or product stays compliant as you grow and iterate.

How We Can Help You with EAA Compliance

Making your website EAA compliant can feel overwhelming, especially with technical standards like WCAG behind the EAA. That’s where WebYes comes in. We help you take the first steps by highlighting the most common accessibility issues, so you’re not starting from scratch.

Here’s how we make it easier:

• Quick accessibility audits: Just enter your website URL to scan for the most common WCAG 2.1 issues – no setup or technical skills required.
• AI-powered fixes: Get AI solutions you can review and paste directly into your code to fix accessibility issues.
• Ongoing checks: Run regular scans to stay on top of new problems and keep your site heading in the right direction.

By helping you meet WCAG 2.2 Level AA – the standard behind Europe’s accessibility rules – WebYes sets you on the path to EAA compliance. Run a free website audit to check if your website is EAA compliant and take the first step toward compliance.