European Accessibility Act: What Irish Online Shops Need to Do Now

The European Accessibility Act (EAA) has applied to online shops selling to consumers in Ireland since 28 June 2025. In Irish law it is S.I. No. 636/2023, and the Competition and Consumer Protection Commission (CCPC) is the compliance authority for e-commerce. If your shop sells to consumers and you are not a microenterprise, your website or app has to be usable by people with disabilities. That means someone who only uses a keyboard, a screen reader, or zoomed text must be able to find a product, add it to the basket, and pay.

The short answer for most Irish shop owners: first check whether you are a microenterprise (fewer than 10 staff and no more than €2 million turnover or balance sheet). If you are, the service requirements don't apply to you, though meeting them is still good business. If you are not, audit your store against WCAG 2.1 Level AA, fix the checkout first, publish information on how your store meets the requirements, and keep records. The rest of this guide covers each step, plus one current change: a new version of the European standard, built on WCAG 2.2, is expected to take legal effect in December 2026.

This guide explains the rules in plain terms for shop owners. It is not legal advice. If you are unsure whether you are covered, the CCPC itself recommends getting independent legal advice.

Does the European Accessibility Act apply to my online shop?

The Act covers a list of products (computers, phones, e-readers, payment terminals and similar) and a list of services. E-commerce services are on the services list. The CCPC describes its role as the market surveillance authority for all covered products and the compliance authority for e-commerce and e-books.

In practice, your shop is in scope if all of these are true:

• You sell to consumers (not only to other businesses) at a distance, through a website or a mobile app.
• You sell to consumers in the EU. The test is where the service is provided, so a shop based outside Ireland that sells to Irish customers is also covered.
• You are not a microenterprise (see below).

It doesn't matter which platform the shop runs on. A Shopify, WooCommerce, Wix or custom-built store carries the same obligation, because the duty sits with the business providing the service, not with the software vendor.

The microenterprise exemption for services

The Directive exempts microenterprises that provide services from the accessibility requirements. The CCPC's microenterprise guidelines define a microenterprise as a business that:

• employs fewer than 10 persons, and
• has an annual turnover of no more than €2 million, or an annual balance sheet total of no more than €2 million.

Three points shop owners often miss:

1. The exemption is for services. The CCPC is explicit that microenterprises dealing in products covered by the Act must still apply the product requirements, unless doing so would fundamentally alter the product or be a disproportionate burden. If you manufacture or import covered products such as e-readers or computers, read that part of the guidelines.
2. Keep evidence. Microenterprises relying on an exception don't need to notify the CCPC, but the guidelines say they should keep the relevant information in case it is requested. A short note with headcount and turnover figures for each year is enough to start.
3. Growth changes your status. Hire your tenth employee or pass the turnover threshold and the exemption no longer applies. If your business belongs to a group, check how staff and turnover are counted before relying on the exemption.

Even if you are exempt, the W3C notes that accessibility benefits everyone: older shoppers, people on small screens, people in bright sunlight. An accessible checkout is a checkout fewer customers abandon.

What the European Accessibility Act requires from an online store

The Directive sets out functional requirements, not a list of website features. For e-commerce, they come down to three things:

• The shop itself must be accessible: perceivable, operable, understandable and robust. These are the four principles of the Web Content Accessibility Guidelines (WCAG).
• Product accessibility information: where the manufacturer or supplier provides accessibility information about a product, the shop has to show it.
• Identification, security and payment steps must be accessible. Sign-in, one-time codes, card entry and payment confirmation are where many shops fail.

Service providers also have to publish information explaining how the service meets the requirements. The Directive places this in the general terms and conditions or an equivalent place, and many businesses publish it as an accessibility statement on the website.

Which standard: WCAG 2.1 AA or WCAG 2.2?

The technical benchmark is the European standard EN 301 549. The version currently in force (V3.2.1) uses WCAG 2.1 Level AA for web content. On 2 September 2026 a new version, EN 301 549 V4.1.1, was published. According to the National Disability Authority, it moves the web baseline to WCAG 2.2 Level AA and is the first version mapped directly to the EAA. It becomes legally significant once the European Commission cites it in the Official Journal, which the NDA says is expected on 16 December 2026. Until then, V3.2.1 remains in force.

What this means for a shop owner, as of November 2026:

• Aim for WCAG 2.2 AA for any new work or redesign. It includes everything in 2.1 AA plus a few additions that matter in shops, such as minimum target sizes for buttons, no re-entering information you have already given, and accessible authentication (no puzzles or memory tests just to log in).
• If you already meet WCAG 2.1 AA, close the gap rather than starting again. Law firm Davis Wright Tremaine recommends a gap analysis against WCAG 2.2 A and AA and a review of your accessibility documentation.

Fines and enforcement in Ireland

Under the Irish regulations, as summarised by DLA Piper and Mason Hayes & Curran, offences can bring:

Route	Maximum penalty
Summary conviction	Class A fine (€5,000) and/or up to 6 months' imprisonment
Conviction on indictment	Fine up to €60,000 and/or up to 18 months' imprisonment

Both the company and its directors, managers and other officers can be found guilty, and a due-diligence defence is available. Consumers can also take a business to court directly, and organisations with a legitimate interest can support them. The likelier first step is that the CCPC directs a business to fix specific problems, but a written record of your audits and fixes is what supports a due-diligence defence.

Many businesses are still behind. In a poll taken during a Mason Hayes & Curran webinar attended by more than 300 professionals (reported in April 2025), 49% of organisations said they were not prepared, and 61% of respondents named technical implementation as their biggest challenge.

Why an accessibility overlay won't fix your shop

Overlays are widgets you add with one line of code that promise to make a site compliant automatically. They are widely sold and widely criticised. In January 2025 the US Federal Trade Commission ordered accessiBe to pay $1 million over claims that its widget could make any website WCAG-compliant. Hundreds of accessibility practitioners have signed the Overlay Fact Sheet, which says overlays do not repair the underlying code and can get in the way of the assistive technology people already use.

The fixes that count live in your theme, templates and checkout: the HTML structure, labels, focus order and contrast. A widget that adds a contrast toggle on top does not change them.

How to check your store: a step-by-step audit

You can do the first pass yourself in an afternoon. The W3C's Easy Checks are a good companion.

1. List your key journeys. Home → category → product → basket → checkout → payment → confirmation. Add account sign-in, returns and the contact form.
2. Unplug the mouse. Do each journey with the keyboard only (Tab, Shift+Tab, Enter, Space, arrow keys). Can you see where the focus is at every step? Can you open the menu, choose a size, close the cookie banner and pay? Any trap or invisible focus is a priority fix.
3. Run an automated checker (a free browser extension such as WAVE or axe) on one page of each type. Automated tools catch only part of the problems, but they find missing labels, empty buttons and contrast failures quickly.
4. Try a screen reader. NVDA (Windows, free) or VoiceOver (Mac and iPhone, built in). Listen to a product page: does it read the product name, price, options and "Add to basket" clearly, and announce when the item is added?
5. Zoom to 200% and test on a phone. Text should reflow without sideways scrolling, and buttons should be big enough to tap.
6. Check the payment step separately. Hosted payment pages and 3-D Secure pop-ups come from your payment provider. Ask them for their accessibility information, and test them yourself.
7. Write it down. Record what you tested, what failed, what you fixed and when. Then publish your accessibility information and a way for customers to report problems.

The online store checklist

Area	What to check
Keyboard	Every link, menu, filter, size picker, basket button and checkout field works without a mouse, with a visible focus outline
Images	Product photos have alt text describing the product; decorative images are hidden from screen readers
Colour and contrast	Text has a contrast ratio of at least 4.5:1 (3:1 for large text); sale prices and errors are not shown by colour alone
Forms	Every field has a visible label; errors say what went wrong and how to fix it; addresses aren't asked for twice
Product pages	Options (size, colour) are real form controls; stock and price changes are announced; accessibility information from the supplier is shown
Checkout and payment	Can be completed by keyboard and screen reader; no time limits without a way to extend; one-time codes can be pasted
Sign-in	No puzzle CAPTCHAs; password managers and paste work; a guest checkout is available where possible
Media	Videos have captions; nothing autoplays with sound; nothing flashes more than three times a second
Structure	One heading hierarchy per page; landmarks for header, navigation, main and footer; page titles describe the page
Pop-ups	Cookie banners and newsletter pop-ups can be reached and closed by keyboard, and focus returns to the page
Information	An accessibility statement explaining how the shop meets the requirements, and contact details for problems

Fix it on your platform, or rebuild?

Most problems in small shops come from three places: the theme, add-ons such as filters, reviews and pop-ups, and the payment step. That points to three realistic routes:

• Fix the theme you have. Good when the audit finds a manageable list: missing labels, contrast, alt text. A developer who knows your platform can often fix these in the templates.
• Switch to a better-built theme or platform. Worth it when the problems are structural, for example a menu or filter system that can't be used by keyboard. Our guides to the best ecommerce platforms and Shopify alternatives compare the options.
• Rebuild around how you sell. Makes sense when you are already planning a redesign, or when your shop has custom steps (made-to-order options, trade accounts, bookings) that themes and add-ons handle badly.

Whichever route you take, accessibility is not a one-off project. Every new product, banner, pop-up or app can break something, so retest whenever the shop changes. That is why ongoing maintenance matters as much as the first fix.

Having your store built with accessibility in mind

Buildly designs, builds, hosts and maintains online stores built around how you sell, on a monthly subscription. Accessibility is easiest and cheapest to get right before anything is built, so it can be part of the plan from the start. Each project goes through approved stages: a written scope, then wireframes (where page structure, focus order and form labels are decided), then design (contrast, text size, button size), then build and launch. You can see the steps on how it works.

Scoping is free: you send a brief and get a written scope and price. A small store with a few products fits the Essential plan at a $35/month launch price (regular $60), with a $100 setup fee and the initial build included. Larger stores with accounts, stock and shipping sit on higher plans; see pricing. Once the store is live, changes such as fixes found in a later audit go through the change requests included in your plan. Buildly doesn't certify compliance; an independent audit is still the way to confirm it.

The bottom line

If you run an Irish online shop with ten or more staff, or more than €2 million in both turnover and balance sheet, the European Accessibility Act applies to you now. Start with the keyboard and screen-reader test of your checkout, fix what blocks a purchase, plan for WCAG 2.2 AA, publish your accessibility information, and keep a record of every step. If you are a microenterprise, write down why you are exempt, and consider fixing the checkout anyway: every shopper who can't finish a purchase is a lost sale.