Ireland · EAA compliance guide

EAA in Ireland — S.I. 636/2023 for developers

Ireland transposed the European Accessibility Act through S.I. No. 636 of 2023 (European Union (Accessibility Requirements of Products and Services) Regulations 2023). Enforced on 28 June 2025. The National Disability Authority (NDA) coordinates compliance guidance, while market surveillance is split between the Competition and Consumer Protection Commission (CCPC) for consumer products and sector regulators for services. Penalties include fines up to €60,000 per offence, and — unusually in EU transpositions — potential imprisonment of company directors for serious repeat breaches.

Legal framework

The Irish legal stack consists of:

  • S.I. 358/2020 — earlier transposition of Directive (EU) 2016/2102 for public-sector bodies.
  • S.I. 636/2023 — transposition of the EAA (Directive 2019/882) to private-sector operators.
  • EN 301 549 — referenced harmonised standard; incorporates WCAG 2.1 Level AA for web content.
  • Disability Act 2005 — pre-existing framework that created the NDA and established broader accessibility duties for public services.

Who it applies to

In-scope services for consumers in Ireland:

  • E-commerce, marketplaces, booking services.
  • Consumer-facing banking and financial services.
  • E-books, e-readers, and related software.
  • Consumer-facing electronic communications (messaging, VoIP, emergency calls).
  • Passenger transport ticketing and real-time information.
  • Consumer hardware and operating systems.

Microenterprise exemption per Article 4(5) of the EAA: fewer than 10 employees and annual turnover / balance sheet under €2M providing services. Product manufacturers are not exempt regardless of size.

Any operator — Irish or non-Irish — offering covered services to Irish consumers falls within the scope. Given Ireland hosts many multinational tech headquarters, the effective reach is broader than the population would suggest.

Technical requirements — EN 301 549

S.I. 636/2023 references EN 301 549 v3.2.1, which incorporates WCAG 2.1 AA. The key conformance targets for web content:

  • Perceivable — alt text, captions for prerecorded video, 4.5:1 body contrast.
  • Operable — keyboard-only operation, no flashing above 3 Hz, focus-visible.
  • Understandable — <html lang="en-IE"> (or the relevant language), predictable navigation, explicit form labels and error messages.
  • Robust — valid HTML, ARIA consistent with DOM semantics.

Penalties and director liability

  • Summary conviction: fine up to €5,000 and/or up to 12 months imprisonment.
  • Conviction on indictment: fine up to €60,000 and/or up to 18 months imprisonment.
  • Continuing offence: additional daily fine up to €1,000 per day of non-compliance.
  • Director personal liability (§35): where an offence is committed by a body corporate with the consent, connivance, or wilful neglect of a director, manager, or similar officer, that person is also guilty of the offence. This is rare in EU transpositions and raises the stakes for persistent non-compliance.

Enforcement is complaint-led in practice. Recognised consumer and disability organisations (DPO) have standing to initiate enforcement proceedings.

Accessibility statement requirements

  1. Conformance status (fully / partially / not conformant with EN 301 549).
  2. Non-accessible content with reason (disproportionate burden, exemption, or in-progress remediation).
  3. Named contact for accessibility feedback (email + phone recommended).
  4. Enforcement procedure pointing to the NDA / relevant sector regulator for escalation.
  5. Methodology of assessment (self-assessment, third-party audit) with date.
  6. Date of preparation and last review.
  7. The statement must itself be accessible; published in English (and, where relevant, Irish).

How to comply — CI-first approach

  1. Baseline scan — axe-core 4.11 against home + critical paths. A typical untuned site shows 30-80 violations.
  2. Fix at source — overlay widgets do not satisfy EN 301 549; regulators and consumer organisations will evaluate the served HTML.
  3. CI pipeline — fail PRs on severity-serious regressions to keep the site clean between audits.
  4. Annual human audit — axe-core catches ~57% of WCAG issues; for the rest engage a certified auditor (IAAP CPACC or similar).
  5. Publish the statement with NDA / regulator escalation details.
  6. Retain evidence — CI scan history is the most defensible record of ongoing diligence.
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