European Accessibility Act in Ireland: S.I. No. 636/2023, who must comply, what's required
Updated 2026-08-07 · European Accessibility Act · Ireland
S.I. No. 636 of 2023 — the European Union (Accessibility Requirements of Products and Services) Regulations 2023 — is how Ireland transposed the European Accessibility Act (Directive (EU) 2019/882) into domestic law. Its accessibility requirements for covered products and services apply from 28 June 2025, the same date as every other EU transposition. This guide covers who the Regulations bind, what they require, and where the primary text sits.
What the Regulations are
Ireland transposed the directive through a statutory instrument rather than primary legislation — a routine mechanism for implementing EU law, and one that carries the full force of law once made. The Regulations set accessibility requirements for the same categories of products and services the directive defines, so that a product or service conformant in one Member State can circulate across the single market without separate national testing.
Who is covered
- Products: consumer computer hardware and operating systems, self-service terminals (payment terminals, ATMs, ticketing and check-in machines, interactive information kiosks), consumer terminal equipment for telecoms and audiovisual media, and e-readers.
- Services: e-commerce, consumer banking services, electronic communications services, services providing access to audiovisual media, elements of air, bus, rail and waterborne passenger transport, and e-books.
For most Irish businesses, e-commerce is the category that matters most in practice: any website or app through which a consumer can conclude a contract at a distance is in scope once the business is above the microenterprise threshold below.
The microenterprise exemption
Service providers with fewer than 10 staff and an annual turnover or balance sheet total not exceeding EUR 2 million are exempt from the service obligations — this is the directive's own EU-wide threshold, unchanged by the Irish transposition. Microenterprises dealing in covered products remain in scope, with reduced documentation duties.
The statement obligation
As under every EAA transposition, providers of covered services must make available information on how the service meets the accessibility requirements — Ireland's counterpart to what Germany documents through Anlage 3 of the BFSG. The information needs to be published somewhere a consumer can actually find it, kept current, and cover the specific service rather than a general statement of intent.
How Irish businesses demonstrate compliance
There is no separate Irish certification scheme. As across the EU, conformance with EN 301 549 — the harmonised ICT accessibility standard, which for web content converges with WCAG 2.1 AA — creates a presumption of conformity with the legal requirements. See our EN 301 549 guide for what the standard actually tests. An independent audit against it, backed by the published statement above, is the evidence base that stands up to scrutiny.
Where to find the primary source
The Irish Statute Book publishes the official, as-made text of S.I. No. 636/2023 — the source to check, not a summary. We do not quote a specific penalty figure for Ireland here: sanctions depend on the nature of the breach and the enforcement route taken in a given case, and a single number pulled out of that context would overstate what any individual business is actually exposed to.
Next step
Run a free scan against the Irish rule set to see how your accessibility statement and technical conformance measure up today, then compare against providers who audit specifically for EN 301 549 / EAA compliance.
FAQ
- What is the Irish law that implements the EAA?
- S.I. No. 636 of 2023 — the European Union (Accessibility Requirements of Products and Services) Regulations 2023 — is Ireland's transposition of Directive (EU) 2019/882. It is a statutory instrument, not a standalone Act of the Oireachtas, but it carries the same binding force: it is the text businesses are assessed against.
- Are Irish micro and small businesses exempt?
- Microenterprises providing services — fewer than 10 staff and annual turnover or balance sheet total not exceeding EUR 2 million — are exempt from the service requirements. This is the EU-wide threshold set by the directive itself, not an Irish-specific carve-out, so it applies the same way in every Member State.
- Does the Regulations apply to a company based outside Ireland selling to Irish consumers?
- The obligation attaches to activity in the market, not to where the company is incorporated. A business established outside Ireland — or outside the EU entirely — that provides covered services or places covered products with Irish consumers falls within scope on the same basis as an Irish-incorporated company.
- Where can I read the actual text of S.I. No. 636/2023?
- The Irish Statute Book publishes the official text of the Regulations as enacted. That is the primary source to check current wording against — not a law-firm client note or an accessibility-tool vendor's summary, both of which paraphrase and can drift from the text over time.