The deadline has passed. The European Accessibility Act applied from 28 June 2025, and in Ireland it is law under the European Union (Accessibility Requirements of Products and Services) Regulations 2023. There is no countdown left to plan around: if your business sells to consumers online, the accessibility requirements apply to you now. This guide sets out where things actually stand, who enforces it here, what still has a later date attached, and what to do if you are behind.
Where things stand in 2026
The Act is Directive (EU) 2019/882, known as the European Accessibility Act or EAA. Ireland transposed it through S.I. No. 636 of 2023, which came into operation on 28 June 2025. Two dates matter for scope:
- Covered products placed on the market on or after 28 June 2025 must meet the accessibility requirements.
- Covered services provided to consumers on or after 28 June 2025 must meet them too. That includes a website that was built years ago but is still trading today.
That second point is the one businesses most often miss. There is no grandfather clause for an old website. If you are still selling through it, it is a service being provided now, and the requirements apply now.
Who needs to act
The Regulations list the services in scope. The ones most Irish businesses will recognise are:
- E-commerce services, defined as services provided at a distance through websites and mobile apps, by electronic means, at a consumer's individual request, with a view to concluding a consumer contract. In plain terms: selling to consumers online.
- Consumer banking services, including consumer credit, payment accounts and related products.
- Electronic communications services, and the answering of 112 emergency calls.
- Services providing access to audiovisual media services, such as streaming and on-demand platforms.
- E-books and dedicated software.
- Elements of passenger transport services, including websites, mobile apps, e-tickets, travel information and self-service terminals.
A purely informational brochure site with no online transaction is not automatically an e-commerce service under that definition. That is a narrower point than most coverage suggests, and it is worth getting a considered view on rather than assuming either way, because booking flows, quote forms that conclude a contract, and online payment all shift a site closer to scope.
The microenterprise position
Microenterprises providing services are outside the service requirements. A microenterprise is one that employs fewer than 10 people and has either an annual turnover not exceeding two million euro or an annual balance sheet total not exceeding two million euro. Note the structure: the headcount test always applies, and only one of the two financial tests needs to be met.
Two cautions. The exemption covers services, not products, so a microenterprise that manufactures or sells a covered product does not get the same pass. And the exemption is a matter of fact, not of declaration: if you grow past the thresholds, the requirements start applying to you. The Competition and Consumer Protection Commission has published guidance for microenterprises and takes a proportionate approach, but it still expects you to be able to show why you believe an exception applies.
Who enforces the EAA in Ireland
Ireland did not create a single accessibility regulator. Enforcement is split between a market surveillance authority for products and sectoral compliance authorities for services:
- Competition and Consumer Protection Commission is the market surveillance authority, and it covers e-commerce services, e-books and dedicated software, consumer computer hardware and operating systems, payment terminals, ATMs and other self-service terminals. For most Irish businesses reading this, the CCPC is the relevant body.
- Central Bank of Ireland for consumer banking services.
- Commission for Communications Regulation for electronic communications services and 112 call answering.
- Coimisiún na Meán for services providing access to audiovisual media services.
- Irish Aviation Authority and the National Transport Authority for the relevant transport service elements.
The National Disability Authority has an advisory role, helping those bodies interpret the requirements rather than enforcing them itself.
The Regulations give these authorities a complaints function: a consumer can complain that a service does not comply, the authority must acknowledge it and, in the normal course, tell the complainant the outcome. Enforcement in practice is largely complaint-led and escalates through requests for information and directions before it becomes anything more serious.
Failing to comply with the accessibility requirements is an offence under Regulation 32. On summary conviction the penalty is a class A fine, which is up to five thousand euro, or up to six months imprisonment, or both. On conviction on indictment it is a fine of up to sixty thousand euro, or up to eighteen months imprisonment, or both. In setting a penalty, a court must have regard to how serious the failure was, how many products or services it affected, and how many people were affected. The realistic risk for a typical Irish SME is not a prosecution out of nowhere; it is a complaint, a request for information you cannot answer, and a remediation deadline you did not choose.
What counts as accessible
In plain language, your website or app should:
- Work well with screen-reading software
- Be usable with only a keyboard or a switch device
- Use colour combinations that everyone can read
- Provide text alternatives for images and captions for video
- Give clear, consistent headings, links and error messages
The technical reference point across Europe is the standard EN 301 549, which builds on the international WCAG guidelines. Aim for WCAG level AA and you are working to the right target. One honest caveat: at the time of writing, the version of EN 301 549 that would carry a formal presumption of conformity for the EAA has not been cited in the Official Journal of the European Union. Following it is strong, defensible evidence of compliance rather than an automatic legal shield, which is another reason to keep a record of what you tested and when.
The requirement people forget: say how you comply
The Regulations do not only ask you to build an accessible service. They also require a service provider to include information assessing how the service meets the accessibility requirements in its general terms and conditions or an equivalent document. In practice that means a genuine, specific accessibility statement rather than a paragraph of good intentions: what the service does, how it is operated, and how the relevant requirements are met. If an authority ever asks, that document is the first thing they will look for.
What still has a later date attached
A few transition provisions are still live, and they are narrower than the headlines suggest. None of them delay the requirement for a website you are trading through today.
- Products already in use to deliver a service. A service provider may continue providing services using products that were lawfully used to provide similar services, up to 28 June 2030.
- Service contracts agreed before 28 June 2025. These may continue without alteration until they expire, but for no longer than five years from that date.
- Self-service terminals. Terminals lawfully in use before 28 June 2025 may continue in service until the end of their economically useful life, but no longer than twenty years after they entered use. This is the provision behind the very long horizons you sometimes see quoted for ATMs and ticket machines.
Separately, some website and app content sits outside the Regulations altogether: pre-recorded video and audio published before 28 June 2025, office file formats published before 28 June 2025, genuine archive content that is not updated or edited on or after that date, third-party content that you neither fund, develop nor control, and online maps where essential navigational information is provided accessibly by other means.
Read those exclusions carefully before relying on one. An old PDF price list is out of scope only while it stays untouched. Edit and republish it, and it is current content again.
If you missed the deadline, what to do now
Missing 28 June 2025 is not an unrecoverable position, and it is a common one. What matters now is that you are visibly working through it on a documented plan rather than hoping nobody looks. Five steps, in this order:
- Confirm whether you are actually in scope. Check the service definitions against what your site really does, and check the microenterprise thresholds against your current headcount and accounts. Write down the conclusion and the date you reached it. Half the businesses worrying about this are exempt, and some who assume they are exempt are not.
- Take an inventory. List every website, app, PDF and video you put in front of customers, and note who looks after each one. Flag anything that concludes a sale or a contract, because that is where scope and risk concentrate.
- Assess and prioritise, do not try to fix everything at once. Test the pages that carry the transaction first: product pages, cart, checkout, account, contact and any booking flow. A fully accessible blog archive is worth very little if the checkout cannot be completed with a keyboard.
- Write the accessibility statement, honestly. Put it in your terms and conditions or an equivalent document, describe how the service meets the requirements, and be candid about what is not there yet and when it will be. A statement that admits a known gap with a fix date reads far better to a regulator than one that quietly overclaims.
- Keep the evidence. Record pages tested, tools and manual checks used, issues found, fixes made and dates. If you are relying on the disproportionate burden or fundamental alteration exception, that assessment has to be documented and retained, renewed at least every five years and whenever the service changes, and you cannot rely on it at all for work that outside funding was provided to do.
How to assess a website yourself
You can get a reliable first read in an afternoon without any specialist software. Work through your most important pages, the checkout above all, and try these:
- Keyboard only. Put the mouse away. Using Tab, Shift+Tab, Enter and the arrow keys, can you reach every link, button, menu and form field, complete a purchase, and always see where you are? A focus outline that has been removed for looks is one of the most common failures we find.
- Zoom to 200 percent. Does the content reflow and stay readable, or does text overlap and disappear off the side?
- Images and video. Do meaningful images carry descriptive alternative text, and are decorative ones marked so a screen reader skips them? Do videos have accurate captions rather than auto-generated approximations?
- Colour and contrast. Run your brand colours through a free contrast checker. Then check that nothing relies on colour alone to convey meaning, such as a red field border with no error message beside it.
- Structure. Are headings real headings in a logical order, rather than bold text made large? Do links say where they go instead of "click here"? Do form fields have visible labels that stay visible once you type?
- Errors. Submit a form with mistakes in it. Is the problem described in words, tied to the right field, and announced rather than only shown in colour?
- An automated scan, with realistic expectations. Free browser tools catch a genuine share of issues, and the rest need a person. Treat a clean automated report as the start of the job, not proof of compliance.
Anything you can fix in your content management system, fix now: alt text, heading structure, link wording, captions. Everything else becomes a scoped brief for whoever maintains the site, and clear notes keep you in control of both the work and the price.
How Brandstart can help
Accessibility is a natural part of building a good website, not a bolt-on. We can scan and manually test your key pages, hand you a to-do list ranked by impact, then implement the code, theme, plugin and content fixes, aiming for compliance without a costly rebuild wherever possible. We work across WordPress, Shopify, bespoke builds and more, and we can polish colours, spacing and navigation so everything stays on-brand while it passes readability tests. We can also draft the accessibility statement so it reflects what your site genuinely does.
Building or rebuilding your site is the ideal moment to get accessibility right from the start. Our web design service bakes WCAG AA thinking into every build, so compliance is designed in rather than patched on later.
The takeaway
The deadline is behind us and the requirements are simply part of trading online now. That is easier to work with than a countdown, because the job stops being a scramble and becomes ordinary maintenance: know whether you are in scope, fix the transaction path first, say honestly how you comply, and keep the evidence. Do that and you end up with a site that is faster, clearer and open to a far wider audience, which was always the better reason to bother.