What changed on 28 June 2025
Web accessibility laws in Ireland changed on 28 June 2025. Since then the European Accessibility Act has applied to consumer services here, through the European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636/2023. If you sell or take bookings from consumers online, you need to be able to show your website complies. Our website accessibility audit tests a site against the standard the law points to, then fixes what fails.
What is the European Accessibility Act, and how does it apply in Ireland?
The EAA, Directive 2019/882, sets common accessibility requirements for listed products and services. The Competition and Consumer Protection Commission confirms it “came into law in Ireland on 28 June 2025”. The Web Accessibility Directive covers public bodies’ own websites and apps; the EAA covers listed products and consumer services, whoever provides them, so in practice it is the law most private businesses meet. It applies to services “provided to consumers on or after 28 June 2025”, so a site that was live before then is still in scope.
Which websites does the European Accessibility Act cover in Ireland?
Regulation 3(2) lists the services in scope:
- Ecommerce services: services provided at a distance through a website or app “with a view to concluding a consumer contract”, such as an online shop, a booking engine or a paid course sign-up. Most businesses land here.
- Consumer banking, and electronic communications such as phone, broadband and messaging.
- Access to audiovisual media, such as streaming and catch-up.
- The digital parts of air, bus, rail and waterborne passenger transport.
- E-books and the software used to read them.
A consumer is a natural person acting outside a trade or profession. A site selling only to businesses sits outside this law, but most customer lists include some private individuals. A brochure site where the sale happens by email or in person may fall outside it, but the definition is wide, so take legal advice if enquiries on your site lead to consumer sales.
Regulation 3(4) excludes video, audio and office documents published before 28 June 2025. Whatever the date, it also excludes online maps whose essential navigational information is available accessibly, third-party content you neither fund, develop nor control, and archives not edited since 28 June 2025. Customer reviews can fall under the third-party exclusion; a widget you pay for and embed may not.
Is my business exempt?
Micro-enterprises providing services. Regulation 5(4) disapplies the service requirements, and the Regulation 14 obligations, for a business with fewer than 10 people and a turnover, or balance sheet total, of no more than €2 million. The CCPC’s guidelines confirm the requirements “do not apply to microenterprises providing services”. A micro-enterprise making, importing or selling an in-scope product still has to comply. The exemption ends once you reach ten staff, or once turnover and balance sheet total both pass €2 million.
Disproportionate burden or fundamental alteration. Regulation 15 limits compliance where a requirement would fundamentally change the service or impose a disproportionate burden. You must document the assessment, tell the regulator you rely on it and produce it if asked. A disproportionate-burden assessment is made against the cost criteria in Schedule 4 and renewed at least every five years. You cannot claim a disproportionate burden if you receive outside funding to improve accessibility.
Transitional periods. Regulation 38 lets service contracts agreed before 28 June 2025 run until they expire, for five years at most. This does not cover 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 covers ecommerce, e-books and dedicated software, so it is the regulator most website owners meet; ComReg, Coimisiún na Meán, the Central Bank, the NTA and the Irish Aviation Authority cover their sectors.
Breaches are criminal offences under Regulation 32. On summary conviction the penalty is a class A fine of up to €5,000, up to six months in prison, or both; on indictment, up to €60,000, up to 18 months, or both. Under Regulation 33, directors and officers who consented to or neglected the failure can be personally liable. A regulator starts with a notice of its intention to give a direction, and you have 14 days for written representations (Regulation 27). Under Regulation 30, a consumer can also apply to the Circuit Court directly for an order requiring compliance.
Which WCAG level do you need?
Build and test to WCAG 2.2 Level AA. 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”, the four WCAG principles. Ecommerce services must also make identification, security and payment steps accessible, and pass on the manufacturer’s accessibility information about the products sold, usually a catalogue field.
EN 301 549, the European standard for ICT accessibility, turns those principles 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 under that Directive. No standard has yet been cited for the Accessibility Act. ETSI published EN 301 549 V4.1.1 on 2 September 2026, moving to WCAG 2.2 and adding an annex that maps it to the Accessibility Act. It gains the presumption of conformity once cited in the Official Journal, expected late 2026.
The W3C states that content conforming to WCAG 2.2 also conforms to 2.1 and 2.0. The exception is Success Criterion 4.1.1 Parsing, which 2.2 removed: if a tender still specifies 2.1, test and report it separately. The criteria 2.2 adds, on focus visibility, target size and not re-entering data, are the ones that stop a purchase on a phone.
A 12-point accessibility 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.
- Use one H1, then H2s and H3s in order, none for styling.
- Check alt text: a description on informative images, an empty alt on decorative ones, never a file name. Both matter for SEO in 2026.
- Check contrast on text, links and buttons: 4.5:1 for normal text, 3:1 for large.
- Confirm nothing relies on colour alone: required fields, errors and “the green button” need a second cue.
- Give every field a visible, attached label, and make errors say what went wrong and how to fix it.
- Zoom to 200% and then 400%: content should reflow into one column with no horizontal scrolling.
- Complete checkout with a screen reader (VoiceOver or NVDA) and note any “button” or “link” announced with no name.
- Caption video, let motion be paused, and let nothing flash more than three times a second.
- Measure tap targets against WCAG 2.2’s 24 by 24 CSS pixels; crowded checkout buttons fail, a layout fault a high-performance website build also fixes.
- Test identification, payment and confirmation closely, since Schedule 1 singles them out, and publish an accessibility statement.
What does an accessibility audit involve?
Automated tools such as axe and Lighthouse catch missing alt text and contrast failures, but cannot tell you whether a screen-reader user can complete a purchase. An audit adds a keyboard and screen-reader pass through the journeys that earn money, a review of documents and video published since 28 June 2025, and a report giving each finding its failed criterion, severity and fix.
Loco Digital designed and built the Just Transition Commission website, launched in February 2026, and in June and July 2026 we audited and fixed accessibility on the live site. The work ships as one plugin of ours that changes no WordPress core, theme or third-party file. On 19 September 2026, axe-core counted 0 WCAG 2.1 A and AA violations across the templates tested, and Lighthouse scored accessibility at 100. The Commission’s published accessibility statement says the site is partially compliant; PDFs were out of scope.
Read the Just Transition Commission case study
What does remediation involve?
- Structure. Fixes to navigation, focus, headings, forms, colour tokens and component states, made in a child theme or small plugin so they survive updates. This clears most issues site-wide and is the groundwork of our web design in Dublin.
- Content. Alt text, documents, captions, link wording and headings, page by page, with publishing rules so new pages do not reintroduce failures.
- Verification. Re-run the scan, re-test the commercial journeys with a keyboard and a screen reader, and publish the accessibility statement Regulation 14(2) requires.
