European Accessibility Act for online shops in Ireland

The European Accessibility Act (Directive (EU) 2019/882) has been enforceable since 28 June 2025. If your business has fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euro, you are exempt as a micro-enterprise from the EAA service obligations. The exemption is automatic -- you do not need to notify anyone. But it is not permanent: if you grow above the threshold, you lose it.

Does the EAA apply to your online shop?

Three questions determine whether the EAA applies to your online shop.

Question 1: Do you sell to consumers in the EU/EEA? What matters is where your customers are, not where your business is. An Irish online shop that delivers to French consumers falls under the EAA for those deliveries.

Question 2: Is it a covered service? E-commerce is a covered service. Other covered services include consumer banking, electronic communications, e-books, passenger transport information and access to audiovisual media services.

Question 3: Are you a micro-enterprise? Fewer than 10 FTEs and an annual turnover or balance sheet total of no more than 2 million euro (Recommendation 2003/361/EC). The test applies to the most recently completed financial year. Both criteria must be met simultaneously: fewer than 10 FTEs and below 2 million.

If you answer "yes" to all three but are a micro-enterprise, you are exempt from the service obligations. Note: if you manufacture, import or distribute products covered by the EAA (e-readers, smartphones, routers, payment terminals), product obligations still apply, though documentation requirements are lighter (Article 4(4)).

Transitional provision: service contracts concluded before 28 June 2025 may run to their natural end, no later than 28 June 2030.

The technical standard: WCAG 2.1 AA via EN 301 549

EN 301 549 V3.2.1 (2021-03) is the harmonised standard that gives technical substance to the EAA. For web content, it points to WCAG 2.1 Level AA. That is the current legal floor.

ETSI is working on V4.1.1 which picks up WCAG 2.2 AA and real-time text updates. Publication is expected early 2026, but V4.1.1 has not yet been cited in the Official Journal of the EU as of April 2026. WCAG 2.2 became ISO/IEC 40500:2025 in October 2025. In practice: building for WCAG 2.2 AA is sensible and future-proof, but WCAG 2.1 AA is what the law currently requires.

Transposition and supervision in Ireland

Ireland transposed the EAA through S.I. No. 636 of 2023 (European Union (Accessibility Requirements for Products and Services) Regulations 2023), signed on 12 December 2023. The regulations came into force on 28 June 2025.

Ireland has designated multiple supervisory authorities. The CCPC (Competition and Consumer Protection Commission) is the primary supervisor for e-commerce and online shops. ComReg covers electronic communications. The Central Bank of Ireland covers financial services. Coimisiun na Mean (the media commission) covers audiovisual media services. The NTA (National Transport Authority) covers passenger transport information.

The NDA (National Disability Authority) and its Centre for Excellence in Universal Design provide guidance and support on accessibility standards, though they are not an enforcement body for the EAA.

Ireland stands out in one significant way: it is the only EU Member State with criminal penalties for EAA non-compliance. On summary conviction, fines of up to 5,000 euro or imprisonment of up to 6 months. On conviction on indictment, unlimited fines or imprisonment of up to 2 years. Ireland has not adopted the built-environment provisions of the EAA.

Enforcement: scaling up, no penalty wave yet

An honest assessment: enforcement is scaling up, but the penalties have not landed yet. The CCPC is beginning with compliance checks and engagement. As of April 2026, no EAA fines or criminal proceedings have been brought against online shops in Ireland.

In other Member States, things are moving faster. France: the NGO Interet a Agir filed formal notices of non-compliance against four major supermarket chains in July 2025. Sweden: PTS opened the first e-commerce cases in late 2025. Norway (EEA): the health authority imposed a daily penalty of NOK 50,000 on the HelsaMi app.

Cross-border cascade risk: findings in one Member State's supervisory system can trigger investigations in others. If your online shop delivers to French consumers and the DGCCRF flags you, that can prompt the CCPC to take notice.

Realistic: compliance engagement and warnings first, criminal proceedings for repeated or wilful non-compliance.

What axe-core actually detects

Deque's own coverage study shows that axe-core detects 57.38% of WCAG issues based on a corpus of 13,000 pages with roughly 300,000 issues found. There are no false positives by design. Other estimates (Playwright, WebAIM) suggest 30-40% when you look at success criteria rather than issue volume. The difference is because contrast, alt text and labels are the most common errors, and those are precisely the ones that are automatically detectable.

Reliably detectable: missing or empty alt text, contrast errors, form fields without labels, missing html lang attribute, landmarks, heading structure, ARIA misuse, duplicate IDs, nested interactive elements, link and button names, autocomplete issues.

Requires manual testing: whether alt text is meaningful, logical reading order, keyboard operability of custom widgets, screen reader output, caption quality, cognitive accessibility, the EAA's CEFR B2 plain-language requirement, contrast against gradients or images, focus management, redundant entry (WCAG 2.2), accessible authentication.

A clean axe-core report is the baseline, not EAA compliance. Scanner output is a technical signal, not a compliance verdict.

The 5 most common online shop failures

WebAIM Million 2026 data: 95.9% of the top 1 million homepages have detectable WCAG errors. Average of 56.1 errors per page. Retail and e-commerce sites average roughly 71 errors per page (27% worse than average). Platform averages: Shopify roughly 70, WooCommerce roughly 76, Magento roughly 85.

1. Low-contrast text. 84% of pages, average of 34 instances. Price labels, sale overlays, placeholder text. WCAG 1.4.3.

2. Missing alt text on images. Roughly 53% of pages. Product photos, category tiles. 45% of missing alt text is on linked images. WCAG 1.1.1.

3. Form fields without labels. Roughly 48-51% of pages. Checkout, search bar, newsletter, payment forms. WCAG 1.3.1 / 3.3.2 / 4.1.2.

4. Empty or ambiguous links and buttons. Roughly 45%. "Read more", icon-only cart button. WCAG 2.4.4 / 4.1.2.

5. Skipped headings and broken document structure. Roughly 39%. WCAG 1.3.1 / 2.4.6.

Honourable mention: ARIA misuse. Pages that use ARIA average 57 errors compared with 27 on pages without ARIA.

What to do if you are in scope

Start with an EN 301 549 / WCAG 2.1 AA baseline audit. Publish an accessibility statement and a user feedback mechanism. The CCPC expects both. Address the top 5 errors. Document any disproportionate-burden decisions if you claim one. The EAA requires that consumer information is written at no more than CEFR B2 level. Plain language is not optional.

The exemption is not a free pass

If you are exempt, be honest about the commercial considerations: roughly a quarter of consumers have a disability, SEO rewards semantic HTML and B2B procurement contracts increasingly impose EAA conformity as a supply-chain requirement. The legal exemption does not exempt you from the market.

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This article is technical analysis, not legal advice. Consult a solicitor for advice on your specific situation.