The European Accessibility Act in Ireland

What S.I. 636/2023 Does

The European Accessibility Act is an EU directive, Directive (EU) 2019/882, so each member state had to write it into national law. Ireland did that through the European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636/2023. The Regulations set accessibility requirements for a defined list of consumer products and services, and those obligations have applied since 28 June 2025.

The reach is wide. The Regulations catch any business selling in-scope products or services to consumers in the EU, regardless of where that business is established. An Irish retailer, a UK brand shipping to Dublin, and a US SaaS company billing Irish consumers are all inside the same net for their in-scope activity.

This page covers the Irish specifics: who enforces the Regulations, why the penalty model stands out, and what to do about it. For the EU-wide picture, start with our European Accessibility Act guide and the deeper EAA research hub.

Who Enforces It: The Six-Regulator Map

Instead of naming one national accessibility authority, Ireland split enforcement across six existing sector regulators. Which one you answer to depends on what you sell:

For most online businesses the practical answer is the CCPC: an inaccessible e-commerce checkout is squarely its territory. A bank's consumer services sit with the Central Bank of Ireland instead, and a business operating across sectors can be answerable to more than one regulator. We cover the sector-specific stakes in our e-commerce accessibility guide and finance accessibility guide.

Penalties: Why Ireland Is Different

Ireland made EAA non-compliance a criminal matter, which is unusual in the EU. Under S.I. No. 636/2023 an offence can be prosecuted two ways:

• On summary conviction: a Class A fine (up to EUR 5,000) and/or up to 6 months imprisonment.
• On conviction on indictment: a fine of up to EUR 60,000 and/or up to 18 months imprisonment.

The sharper edge is personal. Where an offence is committed with the consent, connivance or neglect of a director, manager, secretary or other officer of the company, that individual can be liable as well as the company. A compliance question that lands in most member states as an administrative matter for the business lands in Ireland as potential criminal exposure for named people.

That framing changes how Irish boards should treat digital accessibility: it belongs on the risk register next to other criminal-liability regimes, with documented decisions, not in a backlog of nice-to-have website improvements.

Are You in Scope?

The Directive defines the covered categories, and Ireland enforces the same list. You are in scope if you provide any of these to consumers:

• Consumer-facing e-commerce services
• Consumer banking services
• E-books and e-readers
• Transport services
• Access to audiovisual media services
• Electronic communications services
• Self-service terminals
• Computers and operating systems
• Smartphones

Two points trip people up. First, establishment does not matter: any business selling these to consumers in the EU is covered, wherever it is based. Second, the microenterprise exemption is narrower than its reputation. Service-provider microenterprises (fewer than 10 employees and annual turnover not exceeding EUR 2 million) are exempt from the service requirements, but should be able to provide relevant documentation if relying on the exemption. Microenterprises dealing with products get lighter documentation duties, not a full pass.

If you are unsure where you land, our EAA scope checker walks through the sector, establishment and microenterprise questions in a few minutes.

The Compliance Route: EN 301 549 and WCAG

The Regulations state requirements as outcomes, not techniques. The practical route to meeting them is EN 301 549, the harmonised European accessibility standard. Conformity with the harmonised standard gives a presumption of conformity with the accessibility requirements, which is the strongest position a business can put itself in.

For web content, EN 301 549 incorporates WCAG at Level AA. The currently cited version of the standard is EN 301 549 v3.2.1, and a v4 aligned to WCAG 2.2 is in the ETSI approval pipeline in 2026. Building to WCAG 2.2 Level AA now means you meet the current standard and are already positioned for the next one.

Our WCAG 2.2 checklist covers every success criterion, and the WCAG 2.2 AA requirements guide explains what each one demands in practice.

The 2030 Misconception and Disproportionate Burden

A persistent myth says businesses have until 2030 to comply. They do not. The general obligations have applied since 28 June 2025. The 2030 date comes from two narrow transitional rules:

• Pre-existing service contracts. Service contracts agreed before 28 June 2025 may run unaltered until they expire, but no longer than five years, which caps them at 28 June 2030. This protects specific old contracts, not your website or any new agreement.
• Existing self-service terminals. Terminals lawfully in use before 28 June 2025 may continue until the end of their economically useful life, capped at 20 years.

The other clause businesses reach for is disproportionate burden. It exists, but it is not a self-declared opt-out: a business may claim the requirements impose a disproportionate burden only on the basis of a documented assessment against the criteria in Annex VI of the Directive. Relying on the exemption without that documentation is itself non-compliance.

The safe reading for an Irish business: assume you needed to comply in June 2025, and treat every exemption as something to be evidenced in writing, not asserted after a regulator gets in touch.

What Enforcement Looks Like So Far in Europe

Honest answer: it is early. There is no EU-wide enforcement dataset yet, and the first Commission report on the Directive's application is due 28 June 2030. As of an August 2026 review of primary sources, no monetary fine under an EAA transposition law had been confirmed anywhere in the EU. Two developments show which way the wind is blowing:

• The Carrefour ruling in France. On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour to make its website and app accessible within six months, under a penalty of EUR 500 per day, treating accessibility as an obligation of result rather than an obligation of effort.
• The Dutch regulator's findings. In March 2026 the ACM reported that 61% of the largest Dutch webshops fail accessibility requirements, a signal that regulators are actively measuring the market even before headline fines arrive.

Ireland has its own reason not to wait for a first fine elsewhere: its criminal penalty model means the first Irish enforcement action would look very different from an administrative fine. Track how the EAA compares with other regimes in our accessibility laws tracker, and if you also sell into Great Britain, note that the UK sits outside the EAA and runs its own regime, covered in our UK accessibility law guide.

Practical Steps for Irish Businesses

1. Confirm whether you are in scope. Run your business through the EAA scope checker. If you plan to rely on the microenterprise exemption or a disproportionate burden claim, put the supporting evidence in writing now.
2. Audit against WCAG 2.2 AA. An audit tells you the gap between where you are and what EN 301 549 expects. Our fixed-price WCAG 2.2 AA audits start at $950, and you can see exactly what you get in the sample audit report.
3. Fix the consumer journeys first. Prioritise the flows a regulator or a blocked customer meets first: product pages, cart, checkout, account creation, and support. For online retail, our e-commerce guide maps the highest-risk patterns.
4. Publish accessibility information. Telling customers how your service meets the requirements, and where it falls short, is part of operating in good faith. Our accessibility statement guide explains what to say, and the statement generator gives you a starting draft.
5. Know your regulator. Work out which of the six bodies covers you, and treat correspondence from any of them seriously from the first letter. Given the criminal penalty model, this is a conversation to have with legal counsel early, not after a deadline passes.
6. Keep the evidence current. Retest after significant releases and keep your documentation, assessments and remediation records up to date. The businesses in the worst position under S.I. No. 636/2023 are the ones that can show a regulator nothing at all.

Frequently Asked Questions