The EAA in Ireland: what your online shop must do
In short
In Ireland, the European Accessibility Act is applied by S.I. No. 636 of 2023 — the European Union (Accessibility Requirements of Products and Services) Regulations 2023 — in force since 28 June 2025. If you sell online to Irish consumers — even from abroad — you are very likely covered. Key points:
- e-commerce services are supervised by the Competition and Consumer Protection Commission (CCPC);
- Ireland is the only EU state that attaches criminal penalties to serious non-compliance: on indictment, a fine up to €60,000 or up to 18 months' imprisonment (Regulations 32–33);
- company directors, managers and officers can be personally prosecuted where the offence is committed with their consent or connivance;
- the technical target is EN 301 549, which incorporates WCAG 2.1 level AA; you must also prepare and keep accessibility information about your service.
Ireland is the only English-speaking member of the European Union — so an Irish merchant reading in English is reading about their own law, not a foreign one. And the Irish transposition of the EAA has a feature no other Member State shares: it is backed by criminal, not merely administrative, sanctions. Since 28 June 2025, accessibility is a legal duty for online shops selling into Ireland. Here is what changes in practice, and why the Irish regime deserves a closer look than a quick « it's the same EU rule ».
Which law: S.I. No. 636 of 2023
Ireland transposed the European Accessibility Act — Directive (EU) 2019/882 — through a statutory instrument rather than a standalone Act of the Oireachtas: S.I. No. 636 of 2023, the European Union (Accessibility Requirements of Products and Services) Regulations 2023. Signed at the end of 2023, its substantive obligations began to apply on 28 June 2025, the date fixed across the whole Union. The accessibility requirements themselves are set out in Schedule 1 of the Regulations, mirroring Annex I of the directive.
For an online shop, the obligations that matter are those on service providers, found in Part 5, Regulation 14. Unlike the German BFSG or the Spanish Ley 11/2023, there is no separate, differently named national « accessibility act » to hunt for: in Ireland the obligation lives in this single statutory instrument, and it is written in English.
The Irish particularity: criminal, not just administrative, penalties
This is where Ireland stands apart from every other Member State. Most countries enforce the EAA through administrative fines imposed by a regulator. Ireland instead built the sanctions into the criminal law: under Regulations 32 and 33 of S.I. 636/2023, a breach of the accessibility duties is a criminal offence that can be prosecuted in court.
| Route of prosecution | Maximum penalty | In practice |
|---|---|---|
| Summary conviction (District Court) | up to €5,000 and/or 6 months |
a Class A fine and/or up to 6 months' imprisonment, for less serious breaches |
| Conviction on indictment | up to €60,000 and/or 18 months |
a fine up to €60,000 and/or up to 18 months' imprisonment, for serious breaches |
Who enforces? The CCPC
For products and for e-commerce and related digital services, the market-surveillance authority is the Competition and Consumer Protection Commission (CCPC). The CCPC is explicitly the competent authority for e-commerce services, e-books and dedicated software. It can require a provider to hand over the information needed to demonstrate that the service conforms, can direct an operator to bring a non-compliant service into line, and — if directions are ignored — non-compliance can be pursued through the criminal route described above.
An investigation can be prompted by a complaint — for instance a disabled consumer unable to complete a purchase — or by the CCPC acting on its own initiative. Because the CCPC also publishes plain-English guidance for businesses, « we didn't know » is not a strong position for an Irish or Ireland-facing shop.
The technical standard: EN 301 549 / WCAG 2.1 AA
Ireland does not invent its own technical criteria. As across the Union, a service's conformity is presumed when it meets the harmonised standards whose references are published in the Official Journal of the European Union. For web services, the relevant harmonised standard is EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, level AA.
In practice, the requirements are the same as elsewhere in Europe: sufficient colour contrast, text alternatives for images, keyboard operability, correctly labelled forms, a page structure readable by assistive technology. For e-commerce, the law places particular weight on the accessibility of the identification, security and payment functions of the purchase journey.
The mandatory document: accessibility information
Beyond technical accessibility, a service provider must prepare information explaining how the service meets the applicable accessibility requirements and keep it available for as long as the service is offered (S.I. 636/2023, Part 5, Regulation 14, carrying over Article 13 and Annex V of the directive). It must be made available in an accessible format, in writing, and be produced to the CCPC on request.
This document is immediately verifiable: an inspector does not need to audit dozens of technical criteria to note that it is missing. It is the easiest breach to establish — and, given the Irish penalty regime, one you least want to leave undone.
Is my small online shop covered?
The EAA — and therefore the Irish Regulations — exempts microenterprises that provide services: businesses with fewer than 10 people and an annual turnover or balance-sheet total not exceeding €2 million. If you are under both thresholds and you provide a service, the service obligations do not bite. But the exemption is narrower than it looks: it works differently for products, and most established shops and SaaS businesses exceed one of the two thresholds. Do not assume the exemption without checking it against your actual figures.
The mistake to avoid: « one-click accessibility » overlays
Widgets such as accessiBe or UserWay promise automatic compliance from a single line of code. They do not make you compliant. Their real effectiveness is contested by disability organisations; in the US, the FTC fined accessiBe one million dollars in 2025 over compliance claims found to be misleading. An overlay does not fix your site's source code and does not produce the required accessibility information.
The defensible path is the opposite: audit the site, fix what can be fixed, and publish honest accessibility information documenting the actual state and the plan to close the gaps.
How to comply, in practice
- Audit. An automated technical scan (WCAG 2.1 AA) detects part of the non-conformities — contrast, image alternatives, structure, forms. It does not replace a full manual audit, but it establishes a factual, quantified baseline.
- Fix the priority points — often few and inexpensive (colour contrast, form labels, keyboard operability).
- Prepare the accessibility information, with an accurate conformity status and a contact channel.
- Keep it current: conformity degrades with every deployment. A periodic re-scan avoids drift — and, in Ireland, avoids a criminal exposure quietly re-opening.
Check your exposure in 2 minutes
DeclareAccess scans one page of your site (WCAG 2.1 AA), returns a quantified report of the non-conformities, then generates the ready-to-publish accessibility document — for the Irish, French (RGAA), German (BFSG), Italian, Spanish or Dutch regime. Free audit, no credit card.
WCAG report by email within 24 business hours.
Got it. Your audit request is recorded — you'll receive your WCAG report by email within 24 business hours.
Frequently asked questions
I sell into Ireland from abroad: am I covered?
Yes, very likely. The obligation follows the market you target, not the country of the registered office. As soon as you offer products or services to consumers in Ireland, your activity falls under the Irish Regulations (S.I. 636/2023) for that market. A multi-country shop accumulates the corresponding national regimes.
Which Irish law applies to my online shop?
S.I. No. 636 of 2023 — the European Union (Accessibility Requirements of Products and Services) Regulations 2023 — which transposes Directive (EU) 2019/882. The service-provider obligations relevant to e-commerce are in Part 5, Regulation 14, and the accessibility requirements are in Schedule 1. It applies since 28 June 2025.
Is it true that Ireland has criminal penalties for accessibility breaches?
Yes. Ireland is the only EU Member State that attaches criminal sanctions to serious EAA non-compliance. Under Regulations 32–33, a breach can be prosecuted: on summary conviction a Class A fine (up to €5,000) and/or up to 6 months' imprisonment; on indictment a fine up to €60,000 and/or up to 18 months. These are maximums set by a court, reserved for serious cases — not automatic penalties.
Can a company director be personally liable?
Where a company's offence is committed with the consent, connivance or neglect of a director, manager, secretary or other officer, that individual can also be found guilty under the Regulations. The exposure is therefore not purely corporate.
Does Irish law ask for anything different from WCAG?
Not on the technical substance. Conformity is presumed for a service that meets the European harmonised standards; for the web, the relevant standard is EN 301 549, which incorporates WCAG 2.1 level AA. What is Ireland-specific is the enforcement authority (the CCPC), the mandatory accessibility information, and the criminal penalty regime.
Who enforces accessibility for my online shop in Ireland?
The Competition and Consumer Protection Commission (CCPC) is the market-surveillance authority for e-commerce services under the Regulations. It can require evidence of conformity, direct a provider to comply, and, where directions are ignored, non-compliance can be pursued as a criminal offence. A consumer can prompt an investigation by complaint.
Is my small online shop covered?
The Regulations exempt microenterprises that provide services — fewer than 10 people and annual turnover or balance sheet not exceeding €2M. If you exceed either threshold, you are covered now, and the exemption works differently for products. When in doubt, an audit gives you a factual answer about your site's state regardless of status.
Does an overlay (accessiBe, UserWay) make me compliant?
No. An overlay adds a widget whose effectiveness is contested, does not fix the source code and does not produce the required accessibility information. The compliant approach is to audit the site, fix the non-conformities and publish honest accessibility information.