EAA enforcement in Ireland: CCPC, fines and criminal penalties

Which law applies

S.I. No. 636 of 2023 transposes the Directive and applies from 28 June 2025. Regulation 5(4) disapplies the service accessibility requirements for services provided by a microenterprise, defined as fewer than 10 persons with turnover or balance sheet total not exceeding EUR 2 million. The CCPC has published guidelines for microenterprises.

The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added.

Who enforces it for online shops

The Competition and Consumer Protection Commission (CCPC) is the market surveillance authority for products and the compliance authority for e-commerce services and e-books. ComReg covers electronic communications, the Central Bank covers banking, and other bodies cover transport and media. The National Disability Authority advises but does not enforce (NDA).

How a complaint reaches a shop

The CCPC invites consumers to report concerns through its website and businesses to notify it of non-compliance or of a claimed exemption (CCPC). We found no separate statutory complaint form and no Irish court case on webshop accessibility as of 1 October 2026.

Penalties

Regulation 32 of S.I. 636/2023 makes failing to comply with the core requirements an offence. A person convicted is liable:

• on summary conviction, to a class A fine (up to EUR 5,000) or imprisonment for up to 6 months, or both;
• on conviction on indictment, to a fine of up to EUR 60,000 or imprisonment for up to 18 months, or both.

The court must weigh the seriousness of the failure, the number of products or services affected, and the number of people affected. Few other EU countries attach possible prison terms to these rules.

What has actually happened so far

• 28 June 2025. The CCPC announced the rules and its role, and reminded businesses of their duties (CCPC, Law Society Gazette).
• 2025. The CCPC consulted on and published guidance for microenterprises (CCPC).
• No prosecution, fine or named enforcement case found as of 1 October 2026.

What to do if you sell into Ireland

If you sell to consumers in Ireland and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.

1. Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
2. Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
3. Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
4. Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
5. Re-test after every redesign, theme update or new app, and keep the reports.

A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.