European Accessibility Act in Ireland: Website Guide 2026

What the EAA actually requires

The EAA — Directive (EU) 2019/882 — sets functional accessibility requirements for a defined list of products and services. Ireland's requirements are set out in Schedule 1 of S.I. No. 636/2023. They include making information available through more than one sensory channel, presenting it in understandable and perceivable ways, and designing relevant websites, apps, identification, security and payment functions so people with disabilities can use them.

WCAG is a valuable technical framework for evaluating web content, and relevant harmonised standards or technical specifications may provide a presumption of conformity where the legal conditions are met. A WCAG evaluation is not, by itself, a legal opinion that an organisation complies with every EAA obligation. Scope, service information, support processes and sector-specific requirements also matter.

Who's in scope

The EAA applies to:

• E-commerce services — services provided at a distance through websites or mobile services, at a consumer's individual request, with a view to concluding a consumer contract.
• Banking services — consumer banking, including mobile banking apps.
• Telecoms — phone and internet service providers' customer-facing digital services.
• Passenger transport services — specified website, mobile, ticketing and information elements for air, bus, rail and waterborne transport.
• Services providing access to audiovisual media services.
• E-books and dedicated software.

Products including certain consumer computer systems, smartphones, e-readers and self-service terminals are also covered, but product obligations differ from service-provider obligations. Use the definitions in the regulations and the relevant regulator's guidance rather than assuming that an industry label settles scope.

Who's exempt

• Microenterprises providing services — fewer than 10 employees AND turnover or balance-sheet under €2 million. (Note: micro-enterprises selling in-scope products are not exempt — only services.)
• Fundamental alteration or disproportionate burden may limit particular requirements only where the conditions and assessment rules in the regulations are satisfied. These are not blanket exemptions to claim without evidence.

The EAA service definitions concern services provided to consumers. A service described as B2B may still need careful analysis if consumers can use or contract for it, and other Irish accessibility duties may apply independently. Confirm uncertain scope with the relevant authority or qualified legal adviser.

Enforcement in Ireland

Multiple regulators carry enforcement responsibilities depending on the sector:

• Competition and Consumer Protection Commission (CCPC) — market surveillance for covered products and compliance authority for e-commerce services, e-books and dedicated software.
• ComReg — electronic communications services.
• Central Bank of Ireland — banking and financial services.
• Designated transport authorities — depending on the transport service.
• Coimisiún na Meán — services providing access to audiovisual media services.

The Irish government's EAA overview lists the authorities and their current remits. Regulation 32 provides for a class A fine and/or up to six months' imprisonment on summary conviction, or a fine up to €60,000 and/or up to 18 months' imprisonment on conviction on indictment. The court must consider factors including seriousness and duration.

How WCAG supports a website evaluation

A scoped accessibility evaluation should name the WCAG version and conformance level being used, the pages and processes sampled, the technologies and assistive technologies included, and any limitations. Common web barriers covered by WCAG include:

• 1.4.3 Contrast (Minimum) — body text needs 4.5:1 contrast ratio against its background. Light-grey-on-white body text fails routinely.
• 1.4.11 Non-text Contrast — UI components (buttons, form fields) need 3:1 minimum against adjacent colours. Pale buttons fail this.
• 2.4.7 Focus Visible — keyboard focus needs to be visually apparent. CSS resets that strip focus styles fail.
• 3.3.2 Labels or Instructions — form fields need persistent labels (not just placeholder text). Many modern designs use placeholder-only fields and fail.
• 2.1.1 Keyboard — everything must be operable via keyboard. Hover-only menus fail.
• 4.1.2 Name, Role, Value — custom components (carousels, accordions, modals) must be exposed correctly to assistive technology. ARIA misuse is the most common failure here.
• 1.3.1 Info and Relationships — semantic structure must be machine-readable. Sites using divs everywhere instead of headings, lists, and landmarks fail.
• 1.4.4 Resize text — text must reflow at 200% zoom without loss of functionality.

A practical assessment and remediation sequence

1. Establish legal and service scope. Identify the product or service, consumers, relevant definitions, possible exemption and responsible regulator before making a compliance claim.
2. Define the evaluation. Record representative pages, complete processes such as account creation or checkout, browsers, devices, assistive technologies, WCAG version and known exclusions.
3. Evaluate with complementary methods. Use automated tools for checks they can perform, then manual keyboard, zoom, screen-reader and content review. Involve disabled users where their experience is needed to answer the research question.
4. Triage and remediate. Prioritise barriers that block or seriously impede completion of important tasks. Record the owner, proposed fix, retest result and remaining limitation.
5. Prepare required service information. Where Schedule 3 applies, describe how the service meets relevant accessibility requirements in accessible terms. The responsible organisation should review this information and any public accessibility statement.
6. Keep accessibility in the release process. Retest changed components and journeys, combine automated regression checks with manual review, and provide a usable feedback route.

Common false reassurances we see

• "We ran an automated scanner and got a high score." W3C notes that evaluation tools can assist with accessibility checks but cannot determine accessibility on their own. Manual evaluation remains necessary.
• "Our supplier said it's accessible." Ask which standard and version were used, what pages and processes were evaluated, which technologies were included, what was excluded and what evidence supports the conclusion.
• "We'll add an overlay widget." A widget is not a substitute for evaluating and remediating the underlying content, structure, controls and processes.
• "Our site is mostly text — accessibility doesn't really apply." WCAG covers far more than alt text. Keyboard navigation, focus management, semantic structure, contrast, error messaging, form labelling — all apply to text-heavy sites.

How to commission an audit

Our website accessibility evaluation is scoped by pages, processes, technologies, WCAG version and required evidence. The report records findings and limitations without presenting the work as legal certification. Where remediation requires design or development changes, the client can use its existing team or separately scope implementation with our sister studio digitaldesign.ie.

Primary sources and evaluation guidance

• S.I. No. 636/2023 — European Union (Accessibility Requirements of Products and Services) Regulations 2023
• Government of Ireland: European Accessibility Act overview and regulators
• CCPC: accessibility information for businesses
• W3C: Web Content Accessibility Guidelines 2.2
• W3C: Website Accessibility Conformance Evaluation Methodology

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