European Accessibility Act Compliance in Ireland (S.I. No. 636 of 2023)

Ireland transposed the European Accessibility Act through the European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636 of 2023, made on 12 December 2023 and in operation since 28 June 2025. The Regulations cover electronic communications, access to audiovisual media services, consumer banking, e-books and dedicated software, e-commerce, parts of air, bus, rail and waterborne passenger transport, and the answering of 112 emergency calls, together with a defined list of consumer hardware that includes general purpose computers and their operating systems, payment terminals, ATMs, ticketing and check-in machines, e-readers, and terminal equipment used for electronic communications or for reaching audiovisual media services.

Scan your site free

National law European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636 of 2023. Made on 12 December 2023 by Roderic O'Gorman, then Minister for Children, Equality, Disability, Integration and Youth, under section 3 of the European Communities Act 1972, for the purpose of giving effect to Directive (EU) 2019/882. Notice of the making was published in Iris Oifigiúil on 15 December 2023, and the Regulations came into operation on 28 June 2025 under Regulation 1(2). The Irish Statute Book chronological table of 2023 statutory instruments, updated to 14 August 2026, records S.I. No. 636 of 2023 as not affected by later legislation, so the text as made is still the operative text. Ireland has two official languages, Irish and English, and no Irish-language text of this instrument is published on the Irish Statute Book, so the English citation above is the one to quote. Transposition was late. The deadline in the Directive was 28 June 2022, and the European Commission sent Ireland a reasoned opinion on 14 July 2023 for failure to notify transposition measures, alongside Bulgaria, Cyprus, the Netherlands and Poland. The Regulations were made about five months after that reasoned opinion, roughly eighteen months past the deadline. The department responsible is now the Department of Children, Disability and Equality.

Web standard The Regulations do not name a technical standard. Regulation 16 gives a presumption of conformity to products and services conforming to harmonised standards, or parts of them, whose references have been published in the Official Journal of the European Union. Schedule 1 sets out the functional accessibility requirements that products and services have to meet. As of August 2026 the European Commission's harmonised standards pages list no standard cited under Directive (EU) 2019/882, and the only accessibility list published there is the one for the public-sector directive, so the Regulation 16 presumption has nothing to attach to yet on the private-sector side. For ICT the working reference in Ireland is EN 301 549, published as version 3.2.1, which requires WCAG 2.1 level AA for web content. ETSI has a revision in progress, EN 301 549 V4.1.0, posted as a public enquiry draft in November 2025 and as a further draft in June 2026, and that revision is not yet a published standard. There is no separate Irish national accessibility standard for the private sector. The public-sector regime is set up differently. S.I. No. 358 of 2020 defines the harmonised standard by direct reference to the Annex to Commission Implementing Decision (EU) 2018/2048, which was amended by Implementing Decision (EU) 2021/1339 of 11 August 2021 to cite EN 301 549 V3.2.1, and the National Disability Authority is the monitoring body under Regulation 8(1) of those Regulations.

Enforcement Regulation 4(1) names the Competition and Consumer Protection Commission (An Coimisiún um Iomaíocht agus Cosaint Tomhaltóirí, the CCPC) as the market surveillance authority for products. Regulation 4(2) divides the services among six bodies: the Commission for Communications Regulation (An Coimisiún um Rialáil Cumarsáide, ComReg) for electronic communications and for the answering of 112 emergency calls, Coimisiún na Meán for access to audiovisual media services, the Irish Aviation Authority (Údarás Eitlíochta na hÉireann) for air passenger transport, the National Transport Authority (An tÚdarás Náisiúnta Iompair) for bus, rail and waterborne passenger transport and for self-service terminals in urban, suburban and regional transport, the Central Bank of Ireland (Banc Ceannais na hÉireann) for consumer banking, and the CCPC again for e-books, dedicated software and e-commerce. Under Regulation 4(4) the National Disability Authority (Údarás Náisiúnta Míchumais) advises these authorities on accessibility requirements and has no enforcement function under the Regulations. Regulation 41 puts product complaints with the market surveillance authority and service complaints with the relevant compliance authority, requires a written acknowledgement without delay, and requires the authority to inform the complainant of the outcome within a reasonable period. The CCPC takes accessibility reports through an online form on its website and says that, as it is not an ombudsman, it cannot represent a consumer or act on a consumer's behalf in a dispute with a business. Regulation 30 lets a consumer apply to the Circuit Court for an order directing an economic operator to comply, and Regulation 30(10) lets an organisation with a legitimate interest support that application with the consumer's approval. Penalties under these Regulations are criminal. Regulation 32(6) makes a person guilty of an offence liable on summary conviction to a class A fine, which section 3 of the Fines Act 2010 sets at not more than EUR 5,000, or to imprisonment for up to six months, or to both, and on conviction on indictment to a fine not exceeding EUR 60,000, or to imprisonment for up to 18 months, or to both. Regulation 32(7) directs the court to have regard to the extent and seriousness of the failure, the number of units of products or services involved and the number of people affected. Regulation 34 gives a due diligence defence to a person who proves that they exercised due diligence and took all reasonable precautions. Regulation 35 lets the CCPC, ComReg, the Central Bank of Ireland, the National Transport Authority, the Irish Aviation Authority and Coimisiún na Meán prosecute summary offences that relate to their own functions.

Who has to comply in Ireland

The Regulations apply to businesses that place covered products on the market in Ireland and to businesses that provide covered services to consumers in Ireland. Regulation 3(1) lists the products. Regulation 3(2) lists the services: electronic communications, access to audiovisual media services, parts of air, bus, rail and waterborne passenger transport, self-service terminals in urban, suburban and regional transport, consumer banking, e-books and dedicated software, and e-commerce. Regulation 5(4) disapplies the service accessibility requirements in Regulation 5(3) and the service provider duties in Regulation 14 where the service is provided by a microenterprise, which these Regulations spell as one word and define in Regulation 2 as an enterprise employing fewer than 10 persons with an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Products carry no equivalent exemption. Public bodies sit under a separate regime, the European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020, S.I. No. 358 of 2020, which transposes the Web Accessibility Directive (EU) 2016/2102 and does not reach private businesses.

The deadlines that matter

28 June 2022

EU deadline for transposing Directive (EU) 2019/882. Ireland did not notify transposition measures by this date.

14 July 2023

European Commission sends Ireland a reasoned opinion for failing to notify transposition measures, with two months to respond.

12 December 2023

S.I. No. 636 of 2023 made under the Minister's official seal. Notice of its making published in Iris Oifigiúil on 15 December 2023.

28 June 2025

Regulations come into operation under Regulation 1(2). Products placed on the market and services provided to consumers from this date must comply.

28 June 2030

End of the Regulation 38(1) transition for services provided using products already in lawful use, and the outer limit for service contracts agreed before 28 June 2025.

WCAG 2.2 AA, EN 301 549

Prove your Ireland compliance

Conforma scans your site against WCAG 2.2 AA and EN 301 549 and lists each failure with the page it appears on. It produces a draft accessibility statement built around the headings in Schedule 3 of S.I. No. 636 of 2023, which requires the assessment of how a service meets the accessibility requirements to sit in the general terms and conditions or an equivalent document, and it keeps a dated remediation record you can produce if the CCPC or a sector compliance authority asks. Conforma provides testing and evidence. The judgement on legal compliance stays with you and your advisers.

Scan your site free Read the full EAA guide

Ireland EAA questions, answered

When did the Regulations start to apply, and is there a transition period?

The Regulations came into operation on 28 June 2025, the same date the Act applies across the EU. Products placed on the market and services provided to consumers from that date have to comply. Regulation 38(1) runs a transition to 28 June 2030 for services provided using products already in lawful use, and lets service contracts agreed before 28 June 2025 run to expiry, up to five years. One drafting point is worth knowing. Regulation 38(1)(a) refers to products lawfully used before 28 June 2030, where Article 32(1) of the Directive refers to products lawfully used before 28 June 2025, so read the Irish text with the Directive alongside it. Regulation 38(2) lets self-service terminals lawfully used before 28 June 2025 stay in service to the end of their economically useful life, up to 20 years after they entered use.

Is my small business exempt?

Regulation 5(4) disapplies the service accessibility requirements for a service provided by a microenterprise, and the exemption covers services only. A microenterprise employs fewer than 10 persons and has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Products get no exemption, so an exempt microenterprise still has product obligations if it manufactures, imports or distributes covered hardware. Regulation 5(6) requires the CCPC to provide guidelines and tools to microenterprises to help them apply the Regulations.

Which accessibility standard do I have to meet in Ireland?

The Regulations name no standard. Regulation 16 gives a presumption of conformity to anything conforming to a harmonised standard whose reference is published in the Official Journal, and as of August 2026 no harmonised standard has been cited there under the European Accessibility Act. Schedule 1 of the Regulations is what you have to meet in the meantime. For ICT the working reference is EN 301 549 version 3.2.1, which requires WCAG 2.1 level AA for web content. ETSI has a revision, EN 301 549 V4.1.0, still in draft.

Who enforces the Regulations and what are the penalties?

Enforcement is divided by sector. The CCPC is the market surveillance authority for products and the compliance authority for e-books, dedicated software and e-commerce. Electronic communications go to ComReg, access to audiovisual media services to Coimisiún na Meán, air passenger transport to the Irish Aviation Authority, bus, rail and waterborne passenger transport to the National Transport Authority, and consumer banking to the Central Bank of Ireland. Regulation 32(6) sets the penalty for an offence: on summary conviction a class A fine of up to EUR 5,000 or up to six months in prison or both, and on conviction on indictment a fine of up to EUR 60,000 or up to 18 months or both. No Irish court has applied these Regulations yet, so there is no case law on how the penalties will be used in practice.

This page is a plain-English summary, not legal advice. Check the cited national law for specifics.

Common fixes to check

Most sites fail the same WCAG checks first. Each guide has a plain-language fix and a before/after snippet you can copy.

WCAG 1.1.1 Images must have alt text Every meaningful image needs alt text so screen-reader users know what it shows. Decorative images get an empty alt attribute so they are skipped. WCAG 1.4.3 Text must have enough color contrast Text needs to contrast with its background so people with low vision can read it. The minimum is 4.5:1 for normal text and 3:1 for large text. WCAG 4.1.2 Form fields must have labels Every input, textarea and select needs an associated label so users know what to enter and screen readers can announce the field. WCAG 4.1.2 Links must have discernible text A link needs text that describes where it goes. An icon-only or empty link is announced as just “link”, so screen-reader users have no idea where it leads.

See all fix guides

See where your site stands in seconds

A free scan against WCAG 2.2 AA, a plain-language fix for every issue, and a Ireland-specific accessibility statement when you need one.