Web accessibility laws Ireland: what changed on 28 June 2025
The web accessibility laws Ireland now works under are no longer a future deadline. The European Accessibility Act has applied to services sold to consumers since 28 June 2025, transposed here as the European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636/2023. For websites in Ireland, the Act is already in its enforcement period. If you sell or take bookings from consumers, the question is no longer “will this affect us?” but “can we show that we comply?”
What is the European Accessibility Act, and how does it apply in Ireland?
The EAA, Directive 2019/882, sets one set of EU accessibility requirements for a defined list of products and services. Regulation 1 of S.I. 636/2023 sets the commencement date, and the Competition and Consumer Protection Commission confirms the Act “came into law in Ireland on 28 June 2025”. The Web Accessibility Directive covers public bodies; the EAA covers private business. It applies to services “provided to consumers on or after 28 June 2025”, so a site live before then is not grandfathered.
Which websites does the European Accessibility Act cover in Ireland?
Regulation 3(2) lists the services in scope:
- Ecommerce services: any service delivered at a distance through a website or app that lets a consumer conclude a contract. An online shop, booking engine or paid course sign-up all fit, and most land here.
- Consumer banking.
- Electronic communications (phone, broadband, messaging).
- Access to audiovisual media (streaming and catch-up).
- The digital parts of air, bus, rail and waterborne passenger transport.
- E-books and the software used to read them.
“Consumer” is the key word: a natural person acting outside a trade or profession. A site selling only business-to-business sits outside this law, but check who actually buys from you; a slice of most customer lists is private individuals.
The flip side is worth saying plainly. If a consumer cannot conclude a contract on your site, a brochure site with an enquiry form where the sale happens by email or in person, the Act does not bite. Accessibility is still worth doing, but nobody should sell you compliance you do not owe.
Regulation 3(4) is narrower than it looks. It excludes video, audio and office documents published before 28 June 2025, but also, whatever the date, online maps where essential navigational information is available accessibly, third-party content you neither fund, develop nor control, and archives not updated or edited on or after 28 June 2025. An embedded map or a reviews widget sits outside the Regulations; the page it sits on does not.
Is my business exempt?
Three legitimate routes exist, each with a catch.
The micro-enterprise exemption for services. Regulation 5(4) disapplies the service accessibility requirements, and the Regulation 14 obligations, for a service provided by a micro-enterprise: fewer than 10 people and a turnover, or balance sheet total, of no more than €2 million. The CCPC’s guidelines put it plainly: “the requirements and obligations of the European Accessibility Act (EAA) do not apply to microenterprises providing services”. Note the word services: a micro-enterprise making, importing or selling an in-scope product still complies. The year you hire your tenth person, your website is in scope.
Disproportionate burden or fundamental alteration. Regulation 15 limits compliance where a requirement would fundamentally change the service or impose a disproportionate burden. It is not a box to tick: document an assessment against Schedule 4, keep it, produce it if asked. Cost alone is no defence.
Transitional periods. Regulation 38 lets service contracts agreed before 28 June 2025 run until they expire, five years at most. None of it covers a website you keep publishing.
Who enforces web accessibility laws in Ireland, and what are the penalties?
Regulation 4 names the enforcement bodies. The CCPC is the compliance authority for ecommerce, e-books and dedicated software, the regulator most website owners meet; ComReg, Coimisiún na Meán, the Central Bank, the NTA and the Irish Aviation Authority cover their sectors.
The Regulations create criminal offences. Under Regulation 32, a summary conviction carries a class A fine (up to €5,000) or six months in prison, or both; on indictment, up to €60,000 or 18 months, or both. Regulation 33 extends liability to directors and officers who consented to or neglected the failure. A regulator’s first move is a notice of its intention to give a direction, with 14 days for you to make written representations (Regulation 27). But you do not need a regulator at all: under Regulation 30 a consumer who believes you are non-compliant can apply to the Circuit Court directly for an order requiring compliance. The likely trigger is one customer who could not complete a purchase.
Website accessibility Ireland: which standard and which WCAG level?
The Regulations never name WCAG. Schedule 1 requires websites and apps to be accessible “in a consistent and adequate way by making them perceivable, operable, understandable and robust”. Ecommerce services must additionally make identification, security and payment steps accessible, and pass on any accessibility information the manufacturer provides about the products sold. That last one is a product-data job rather than a front-end one, and usually means a catalogue field nobody has filled in.
Those four are the WCAG principles, and EN 301 549, the European standard for ICT accessibility, turns them into a testable checklist. Its v3.2.1, cited in the Official Journal in August 2021 under the Web Accessibility Directive, builds on WCAG 2.1 Level AA and still carries the presumption of conformity. It has a successor: ETSI published EN 301 549 V4.1.1 on 2 September 2026, moving to WCAG 2.2 and adding an annex mapping the standard to the Accessibility Act itself. It carries no presumption of conformity until cited in the Official Journal, expected late 2026.
So build and test to WCAG 2.2 Level AA now. The W3C states that content conforming to WCAG 2.2 also conforms to WCAG 2.1 and 2.0, so one piece of work meets today’s standard and its successor, with one wrinkle: 2.2 removed Success Criterion 4.1.1 Parsing, so if a tender still specifies 2.1, that criterion is tested and reported separately. The extra 2.2 criteria, focus visibility, target size and not re-entering data, are what stops a purchase on a phone.
European Accessibility Act websites Ireland: a 12-point self-check
- Using only the keyboard, operate every menu, link, button, field and popup, and always see where focus is.
- Check cookie banners, chat widgets and modals do not trap focus, and Escape closes what Enter opened. Focus is a conversion and UX problem too.
- Inspect the heading structure: one H1, then H2s and H3s in order, none used for styling.
- Check alt text: a description on informative images, an empty alt attribute on decorative ones, never a file name. Both matter for SEO in 2026.
- Run a contrast checker on text, links and buttons: 4.5:1 normal, 3:1 large.
- Confirm nothing relies on colour alone. Required fields, errors and “the green button” need a second cue.
- Check every field has a visible, attached label, and errors say what went wrong and how to fix it.
- Zoom to 200% and then 400%. Content should reflow into one column, no horizontal scrolling.
- With a screen reader (VoiceOver or NVDA), complete checkout and note anything announced “button” or “link” with no name.
- Check video has captions, motion can be paused, and nothing flashes three times a second.
- Measure tap targets: WCAG 2.2 expects 24 by 24 CSS pixels. Crowded checkout buttons fail, as do the layout faults a high-performance website build fixes.
- Test identification, payment and confirmation closely, since Schedule 1 singles them out, and publish an accessibility statement.
What does an accessibility audit involve?
An automated scan is where an audit starts. Tools such as axe and Lighthouse catch missing alt text and contrast failures. Whether a screen-reader user can actually buy is a separate question. A proper audit adds a manual keyboard and screen-reader pass through the journeys that matter commercially, a review of documents and video published since 28 June 2025, and a report mapping each finding to the criterion it fails, with a severity and a fix. On WordPress it separates theme and plugin faults, fixed once in code, from content fixed page by page.
For us, accessibility is a way of building rather than a line item. On ERP HEADtoHEAD, Lumenia’s event site, colour tokens were documented with contrast ratios verified rather than judged by eye, and the booking engine was written as a dedicated plugin in vanilla JavaScript with no front-end framework, so the four-step delegate flow is plain, testable markup rather than a component tree nobody can keyboard through. The same goes for every website and ecommerce build.
What does remediation involve?
Remediation has three layers. The first is structural: template-level fixes to navigation, focus management, headings, form markup, colour tokens and component states, made in a child theme or small plugin so they survive updates. That clears most issues site-wide, and is the groundwork behind any web design in Dublin build.
The second is content: alt text, documents, captions, link wording and headings, page by page. It never finishes, because every new page can reintroduce a failure, so it comes with publishing rules for whoever edits the site.
The third is verification: re-running the scan, re-testing the commercial journeys with a keyboard and a screen reader, and publishing the accessibility statement, which a regulator asks for first.
