The EU Accessibility Act (EAA) took effect on 28 June 2025. The EAA was transposed into Irish law under the European Union (Accessibility Requirements of Products and Services Regulations 2023) (EAA Regulations). The EEA Regulations contains the EAA accessibility requirements as well as information on the six different authorities in Ireland that will be responsible for regulating the products and services.
The EAA aims to harmonise accessibility standards across the EU, ensuring that persons with disabilities have equal access to key products and services.
Products and Services in scope
The EAA Regulations apply to the following products placed on the market:
- consumer general purpose computer hardware systems and their operating systems;
- payment terminals;
- self-service terminals such as ATMs, ticketing machines, check-in machines and interactive self-service terminals providing information;
- consumer terminal equipment with interactive computing capability, used for electronic communications services or for accessing audiovisual media services (e.g. smartphones); and
- e-readers.
The EAA Regulations also apply to the following services provided to consumers:
- electronic communications services, other than transmission services used for the provision of machine-to-machine services;
- services providing access to audiovisual media services;
- websites, mobile device-based services including mobile applications, electronic tickets and electronic ticketing services, delivery of transport service information, including real-time travel information and interactive self-service terminals located within the territory of the EU for air, bus, rail and waterborne passenger transport services;
- interactive self-service terminals located within the territory of the EU for urban and suburban transport services and regional transport services
- consumer banking services;
- e-books and dedicated software; and
- e-commerce services (being “services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract”).
Accessibility Requirements
Economic operators (manufacturers, authorised representatives, importers, distributors and service providers) who place in-scope products and services on the market must comply with the accessibility requirements in the EAA, with different obligations specified for the different economic operators.
Schedule 1 of the EAA Regulations outlines general and specific accessibility requirements that apply to the relevant products and services. From a high level, products must be designed and produced in such a way as to maximise their foreseeable use by persons with disabilities and must be accompanied by accessible information on their functioning and accessibility features. Information on products and the operation of user interface must be understandable and meet a diverse range of user's accessibility needs.
For microenterprises, the EAA’s product requirements apply, but service-related obligations do not.
Compliance
While the EAA outlines what it requires, the EAA does not prescribe how to achieve compliance, allowing for innovation in how companies design and deliver compliant products and services.
Where products and services comply with harmonised EU standards, they will be assumed to comply with EU accessibility requirements. Examples of current EU standards include EN 301 549: Accessibility requirements for ICT products and services and EN 17161: Universal Design approach for products, goods, and services with additional new standards to be drafted.
Exemptions
Exemptions from the EAA and EAA Regulations apply in the following circumstances:
- Fundamental alteration: If compliance would fundamentally change the nature of the product or service
- Disproportionate burden: If the cost or effort of compliance is excessive relative to the benefit
If an economic operator is relying on one of the above exemptions, it must be set out in a documented assessment and notified to the market surveillance authority.
Microenterprises are not required to notify authorities when relying on these exemptions but must maintain relevant documentation for inspection.
Competent Authorities and Enforcement
The Competition and Consumer Protection Commission (CCPC) is the market surveillance authority for products, while compliance authorities for services vary by sector. Below are the competent authorities for services in Ireland:
Services | Authority |
In-scope electronic communications services | Commission for Communications Regulation |
Services providing access to audiovisual media services | Coimisiún na Meán |
In-scope elements of air passenger transport services | Irish Aviation Authority |
In-scope elements of bus, rail and waterborne passenger transport services | National Transport Authority |
Consumer banking services | Central Bank of Ireland |
E-books and dedicated software and e-commerce services | CCPC |
Answering emergency communications to the single European emergency number ‘112’ | Commission for Communications Regulation |
Enforcement measures include fines (up to €5,000 on summary conviction, up to €60,000 on indictment) and imprisonment. Company officers may be held personally liable for offences committed with their consent or due to their neglect.
Transitional Provisions
The EAA Regulations provide that a service provider may, up until 28 June 2030, continue to provide their services using products which were lawfully used by them to provide similar services before that date. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date.
Self-service terminals such as ATMs and payment terminals which were used lawfully by service providers for the provision of services before 28 June 2025 may continue to be used in the provision of similar services until the end of their economically useful life but no longer than 20 years after their entry into use.
For more information, please contact Máire Cunningham, Head of Knowledge, or your usual contact in Beauchamps.
