Digital accessibility law in Ireland: who has to comply

Ireland implemented the European Accessibility Act through a statutory instrument that has applied since 28 June 2025. For online shops, the Competition and Consumer Protection Commission is in charge. Here is who is covered, what sets Ireland apart, and what applies to public bodies.

The law in brief

The European Union (Accessibility Requirements of Products and Services) Regulations 2023 were made on 12 December 2023 as S.I. No. 636 of 2023. They implement Directive (EU) 2019/882, the European Accessibility Act (EAA), and came into operation on 28 June 2025. We found no amending instrument.

Who is covered?

Regulation 3 lists the services covered when they are provided to consumers:

• e-commerce services,
• consumer banking services,
• electronic communications services,
• services providing access to audiovisual media services,
• elements of air, bus, rail and waterborne passenger transport, such as websites, apps and electronic tickets,
• e-books and dedicated software.

For a website, the first point is the one that matters. The Regulations define e-commerce services as services provided at a distance, through websites and mobile services, at the individual request of a consumer with a view to concluding a consumer contract. An online shop or a booking site is covered; a site that only presents a business is not.

Some content is excluded, including pre-recorded media and office files published before 28 June 2025, third-party content the operator neither funds nor controls, and archives that are no longer updated.

The microenterprise exemption

The accessibility requirements and the service-provider obligations do not apply to a service provided by a microenterprise (Regulation 5(4)). A microenterprise employs fewer than 10 persons and has an annual turnover or an annual balance sheet total of no more than €2 million.

The exemption covers services only. A microenterprise that manufactures, imports or distributes covered products is still bound. The CCPC publishes guidelines for microenterprises and encourages them to work on accessibility anyway.

Disproportionate burden and transitional periods

Regulation 15 allows a business to depart from the requirements where they would fundamentally alter the service or impose a disproportionate burden. This comes with conditions:

• the business has to carry out and document the assessment and keep the record for five years,
• a service provider has to renew the assessment when the service changes, when the authority asks, and at least every five years,
• a business relying on the exception has to inform the relevant authority; microenterprises are exempt from this duty.

Regulation 38 sets transitional periods. Service contracts agreed before 28 June 2025 may run unaltered until they expire, for five years at most. Products already in lawful use may continue to be used until 28 June 2030, and self-service terminals until the end of their useful life, for 20 years at most. None of this postpones the obligation for the content of a website.

Telling the public

A service provider has to explain how the service meets the accessibility requirements, in the general terms and conditions or an equivalent document (Schedule 3). The information has to be available to the public in writing and orally, including in a form accessible to persons with disabilities. What such a text contains is described in our article on the accessibility statement.

Who enforces the law?

Regulation 4 splits enforcement by sector:

The National Disability Authority (NDA) advises these authorities but does not enforce. Where an authority finds non-compliance, it directs the business to take corrective action within a set period. The business can make representations beforehand and appeal to the District Court.

Penalties

Regulation 32 makes non-compliance an offence:

• On summary conviction: a class A fine, which under the Fines Act 2010 means up to €5,000, or imprisonment for up to 6 months, or both.
• On conviction on indictment: a fine of up to €60,000 or imprisonment for up to 18 months, or both.

The court has to take into account how extensive and serious the failure is and how many people are affected. Directors and managers can be personally liable where an offence was committed with their consent or through their neglect.

The consumer route

Under Regulation 30, a consumer may apply to the Circuit Court for an order directing a business to comply. Organisations with a legitimate interest may support the consumer in doing so. The orders listed are a declaration of non-compliance and an order to comply within a set period.

What has happened so far

We found no published direction, prosecution or court application under the Regulations. The CCPC says it will take a proportionate approach; its guidelines mention fines and imprisonment for exceptional cases. The absence of published cases does not mean nothing is being checked.

Which technical standard?

The Regulations name neither WCAG nor EN 301 549. They set functional requirements and presume conformity where a service meets harmonised standards referenced in the Official Journal of the European Union (Regulation 16). The CCPC points to EN 301 549 as a key standard. In practice that means WCAG 2.1 at level AA, which the standard adopts for the web.

Public bodies

Websites and apps of public bodies fall under separate rules: the European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020, S.I. No. 358 of 2020. Public bodies have to publish an accessibility statement and keep it up to date. The NDA is the monitoring body.

The NDA published its monitoring report for 2025 in December 2025:

• 233 websites received a simplified review, 22 websites and 12 apps an in-depth review.
• The average accessibility score was 55.25%, up from 46.1% in 2024.
• About one site in five scored 90% or more.
• PDF errors were the most common error type on 68% of sites.
• Of the 22 websites reviewed in depth, 27% had no accessibility statement and one met all requirements.

The NDA stresses that the score comes from automated testing and is an indicator, not a measure of legal compliance. On PDFs, see our article on accessible PDFs.

Separately, section 28 of the Disability Act 2005 requires public bodies to make electronic communications accessible to people with a visual impairment as far as practicable.

Below the threshold: the Equal Status Acts

The Equal Status Acts apply to service providers of every size. They require a provider to do all that is reasonable to accommodate the needs of a person with a disability, unless that would cost more than a nominal amount. Complaints go to the Workplace Relations Commission. The Acts do not mention websites, and we found no decision that applies them to an inaccessible commercial website.

Selling into Ireland from abroad

The EAA follows the market, not the registered office. The CCPC puts it this way: the EAA applies to any business that wishes to provide the relevant services in the EU, regardless of where that business is based. A shop in the United Kingdom or the United States that sells to consumers in Ireland is covered. How other EU countries implemented the directive is shown in The EAA across Europe; the background is in our article on the European Accessibility Act.

What we did not check

We read S.I. No. 636 of 2023 as made. We did not check every official register for amendments. We did not review the CCPC annual report for 2025, and we did not research whether the EAA applies within Northern Ireland. This article is not legal advice.

Sources

• S.I. No. 636 of 2023 – Irish Statute Book
• Fines Act 2010, section 3 – Irish Statute Book
• European Accessibility Act becomes law in Ireland – CCPC
• EAA guidelines for microenterprises – CCPC
• European Accessibility Act – Central Bank of Ireland
• S.I. No. 358 of 2020 – Irish Statute Book
• Ireland’s Annual Monitoring Report 2025 – National Disability Authority
• Disability Act 2005, section 28 – Irish Statute Book
• Equal Status Act 2000 – Irish Statute Book
• Equal status complaints – Workplace Relations Commission
• EN 301 549 v4.1.1 adopted – Luxembourg government accessibility portal (in French)