The European Accessibility Act (EAA) came into force on June 28th 2025, imposing a new set of regulations on a wide range of goods and services sold within the EU. This updated legislation will make life significantly easier for an estimated 87 million disabled EU citizens, ensuring that everyday services are accessible, usable, and uniform across each member state.
As I have discussed in previous blogs, the definitions around accessibility have been made quite clear within this legislation. In general, we will see the EAA applied to all digital services sold within the EU (including e-commerce sites and platforms) as well as to banking and transport services. Typically these solutions will require WCAG 2.2 AA compliance (more about what this means here) and there will be very few possible exemptions.
What has been unclear, however, is how these regulations will be enforced. As each member state is responsible for prosecuting non-compliance, this will result in a wide variety of penalties across countries. After two months of careful research, the Kooba accessibility team finally have a clear picture of what this may realistically look like in Ireland.
Fines and legal penalties
In Ireland, the EAA is implemented by S.I. No. 636/2023 (you can read it yourself here). This legislation lays out all the details that business owners need to know about this new regulatory environment. We’ve summarised it below:
First of all, who checks?
Enforcement in Ireland is shared across sector regulators rather than a single central body. For example, the Competition and Consumer Protection Commission oversees e-commerce and e-books, the Central Bank of Ireland covers consumer banking services, and the National Transport Authority is responsible for bus, rail, and waterborne passenger transport. As I argued in my last blog, this might make certain agencies (transport for instance) more likely to see immediate enforcement.
What exactly do they look at?
- Conformance with EN 301 549 and WCAG A or AA, including areas such as keyboard access, focus order, closed captions, and colour contrast.
- The presence and accuracy of your accessibility statement or information page. Even if you are not compliant, it is important to clarify this with a statement!
- Any “disproportionate burden” claim (if applicable), supported by a written and reasonable assessment.
How enforcement works
- The regulator most relevant to your industry will review your service.
- If issues are found, you receive a direction to remedy. This sets out what is wrong, what must be fixed, and by when.
- You implement the fixes and confirm completion. Your solution will then be audited again.
- If you do not meet the deadline, the regulator can escalate with further orders, fines, or prosecution.
Penalties in Ireland
- On summary conviction, a Class A fine up to €5,000 and or up to six months imprisonment.
- On conviction on indictment, a fine up to €60,000 and or up to 18 months imprisonment.
It is worth noting that here is no legal requirement to achieve a 100 percent accessibility score. What matters is meeting the applicable standards, publishing an accurate statement, and remedying any non conformance identified by the regulator. That said, Kooba have already delivered scores at or near 100 for a range of clients (see my previous blog for more).
Your next steps
The enforcement of the EAA may be convoluted and complicated, but the path to compliance is not. By performing an accessibility audit, identifying high-priority issues, and undertaking remediations, Kooba can provide compliance within a tight timeframe.
If you’re looking for compliance (and peace of mind), just get in touch with our team today.
