S.I. No. 636 OF 2023 · CCPC ENFORCEMENT

EAA compliance in Ireland — S.I. No. 636 of 2023

The European Union (Accessibility Requirements of Products and Services) Regulations 2023 transpose the EAA into Irish law. CCPC enforcement is active since June 28, 2025. Scrutia audits your site against WCAG 2.1 AA and delivers fix code.

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S.I. No. 636 of 2023: Ireland's EAA transposition

The European Union (Accessibility Requirements of Products and Services) Regulations 2023 (Statutory Instrument No. 636 of 2023) are the Irish regulations transposing the European Accessibility Act into national law. Signed by the Minister for Enterprise, Trade and Employment in December 2023, the regulations entered into force for most obligations on June 28, 2025.

The regulations designate the Competition and Consumer Protection Commission (CCPC) as the primary enforcement authority, with sector-specific bodies (ComReg, Central Bank of Ireland, NTA) handling specialized sectors. The technical baseline is EN 301 549, which incorporates WCAG 2.1 Level AA.

Official reference: Irish Statute Book — S.I. No. 636 of 2023

Why Ireland matters for global tech companies

Ireland hosts the EU headquarters of many US tech giants — Meta, Google, Apple, Microsoft, LinkedIn, X, Stripe, Intercom — because of its favourable tax regime and English-speaking workforce. This means the Irish EAA regulations are directly relevant to the consumer-facing services these companies provide across the EU through their Irish entities.

The CCPC has indicated that enforcement of large, high-visibility services will be a priority to demonstrate the effectiveness of the Irish transposition. Irish-based tech companies should not assume that their global accessibility programmes automatically satisfy Irish legal requirements — the regulations require documentation and an accessibility statement.

Covered services

  • E-commerce — online retail, marketplaces, subscription services
  • Banking and payments — AIB, Bank of Ireland, Revolut, Stripe consumer services
  • Transport — Irish Rail, Dublin Bus, Aer Lingus, Ryanair
  • Telecommunications — Vodafone, Three, Eir, Sky Ireland
  • Consumer software and SaaS delivered to Irish users

Sanctions under Irish law

  • Summary offence: fines up to €5,000 and/or 6 months' imprisonment
  • Indictable offence: fines up to €60,000 and/or 18 months' imprisonment
  • Continuing offence: €500 per day of continuing non-compliance
  • Compliance notices, corrective action plans, service withdrawal

How Scrutia helps

Scrutia automates the WCAG 2.1 AA assessment that underpins Irish EAA compliance. The audit uses a real browser to test keyboard navigation, ARIA components, contrast, forms, and responsive behaviour — the technical areas the CCPC is expected to scrutinize.

The full report (149 €) includes HTML/CSS/JS fix code for every issue and is designed to support the accessibility statement required under the regulations.

See also the wider EAA audit guide.

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Irish EAA regulations FAQ

What are the Irish EAA Regulations 2023?
The European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636 of 2023, are the Irish statutory instrument transposing the European Accessibility Act (Directive 2019/882) into Irish law. Signed by the Minister for Enterprise, Trade and Employment in December 2023, the regulations have been in force since June 28, 2025, aligned with the EAA-wide deadline.
Who enforces the EAA in Ireland?
The Competition and Consumer Protection Commission (CCPC) is the competent authority designated by the regulations for most products and services. For specific sectors, other bodies share enforcement responsibility: the Commission for Communications Regulation (ComReg) for telecoms, the Central Bank of Ireland for banking, and the National Transport Authority for transport services. All bodies cooperate with the CCPC.
Which Irish companies are covered?
The regulations cover private companies providing digital products and services to Irish consumers, including e-commerce, banking, transport booking, e-books, telecoms, and consumer software. Thresholds follow the EAA: micro-enterprises with fewer than 10 employees AND less than €2 million in annual turnover are exempt. US tech companies with EU headquarters in Dublin — including Meta, Google, and Apple — fall fully within scope for their EU consumer-facing services.
What technical standard applies in Ireland?
Irish EAA compliance references EN 301 549, the harmonized European standard, which incorporates WCAG 2.1 Level AA for web content. The National Disability Authority (NDA) publishes Irish guidance on digital accessibility and operates the Centre for Excellence in Universal Design (CEUD), which is the Irish expert body supporting compliance. Meeting WCAG 2.1 AA is the path to compliance with S.I. No. 636 of 2023.
What fines apply in Ireland?
The regulations provide for criminal and administrative sanctions. Summary offences carry fines up to €5,000 and/or 6 months' imprisonment. Indictable offences carry fines up to €60,000 and/or 18 months' imprisonment, with additional daily penalties of €500 for continuing offences. The CCPC can also issue compliance notices, require corrective action plans, and order the withdrawal of non-compliant services from the Irish market.

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