Does the European Accessibility Act Apply to My Irish E-commerce Site?

What the EAA actually requires for e-commerce, in plain terms

The EAA — Directive (EU) 2019/882 — defines an "e-commerce service" as a service provided at a distance, through a website or mobile-based service, at a consumer's individual request, with a view to concluding a consumer contract. In practice, that covers most Irish online shops: if a person can browse, add to basket and pay for something as an individual consumer, the sales channel is very likely an e-commerce service for EAA purposes — regardless of whether what's being sold is a physical product, a digital download, or a booking.

Schedule 1 of S.I. No. 636/2023 sets out functional requirements rather than a fixed technical checklist: information needs to be available through more than one sensory channel, presented in ways people can perceive and understand, and the site's identification, security and payment functions need to be usable by people with disabilities. That reaches account creation, product browsing, the cart, checkout, and payment — not just the homepage.

WCAG is a useful technical framework for evaluating the website and app elements against many of these functional requirements. But a WCAG scan or sampled evaluation is not, on its own, a legal opinion that an e-commerce service meets every EAA obligation — scope, sampling, third-party components and the parts of the journey actually tested all matter to what a report can honestly claim.

Who's exempt

• Microenterprises providing services — under 10 employees and annual turnover or balance-sheet total under €2 million — are exempt from the EAA's service obligations. If your e-commerce operation genuinely meets both limbs of that test, the CCPC's guidance confirms the requirements do not apply to you as a service provider.
• Products are different. If you also manufacture, import or distribute in-scope products — self-service terminals, e-readers, certain computer hardware — the microenterprise services exemption does not carry over to those product obligations. Selling through a small shop doesn't exempt a covered product.
• Fundamental alteration or disproportionate burden can limit specific requirements, but only where the regulations' assessment conditions are met and the reasoning is documented — it isn't a general opt-out to assert without evidence.

A borderline case worth checking directly: sites that describe themselves as "B2B only" but still let an individual complete a purchase as a consumer. The EAA's service definition turns on consumer contracting, not on how a business markets itself, so this is worth confirming rather than assuming.

Which regulator enforces it, and what evidence they expect

The Irish government's EAA overview names the Competition and Consumer Protection Commission (CCPC) as the compliance authority for e-commerce services (alongside e-books and dedicated software), and as market surveillance authority for the covered products. The CCPC's own guidance for businesses sets out what it expects service providers to be able to show: documented information on how the service meets the applicable accessibility requirements, including relevant design decisions, kept for as long as the service continues to operate. Product-based operators face a separate, heavier documentation duty — technical files and an EU declaration of conformity retained for five years.

If you're relying on the microenterprise exemption or on another exception, read the CCPC guidance and the regulations directly and keep the evidence the applicable rule requires. The regulations give authorities enforcement powers and create offences for specified failures, including failure to comply with certain directions or orders. That is a reason to get qualified advice on a disputed case, not a reason to treat a website audit as a legal sign-off.

A practical self-check before commissioning an evaluation

Before you brief anyone for an accessibility evaluation, it's worth working through this yourself so the scope and quote you get back are actually useful:

1. Confirm the microenterprise test with real numbers. Get headcount and the last full year's turnover or balance-sheet total from your accountant rather than estimating — the exemption depends on both limbs, not a general sense of being "small."
2. List every consumer-facing digital step in a purchase, not just the storefront: account creation and login, product browsing and search, cart, checkout, payment (including any third-party payment provider's own screens), order confirmation and order tracking.
3. Note anything you don't fully control, such as a hosted checkout, a marketplace listing, or an embedded payment widget — scope and responsibility for these should be discussed explicitly with an evaluator rather than assumed.
4. Check whether you already have an accessibility statement or prior audit, and if so, what standard and version it used.
5. Decide, even roughly, which WCAG version and conformance level you want an evaluation measured against before you ask for quotes — it changes both scope and cost, and a credible supplier will ask you this anyway.

If you'd rather have this done for you, our accessibility evaluation is scoped by exactly these questions — pages, journeys, WCAG version and required evidence — before work starts.

Primary sources and evaluation guidance

• S.I. No. 636/2023 — European Union (Accessibility Requirements of Products and Services) Regulations 2023
• Government of Ireland: European Accessibility Act overview and regulators
• CCPC: European Accessibility Act obligations for businesses
• CCPC: European Accessibility Act guidelines for microenterprises
• W3C: Web Content Accessibility Guidelines 2.2
• W3C: Website Accessibility Conformance Evaluation Methodology

Read next

• European Accessibility Act in Ireland: full website guide 2026
• Does the EAA apply to my Irish consumer banking service?
• Does the EAA apply to my Irish passenger transport business?
• Accessibility audit service details

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