What the EAA actually requires for passenger transport, in plain terms
For air passenger services, and for bus, rail and waterborne services other than urban, suburban and regional services, the Irish government's current overview lists websites and mobile apps, electronic tickets and ticketing, transport information (including real-time information) and specified interactive self-service terminals. For urban, suburban and regional services, the EAA coverage is narrower: the overview identifies specified interactive self-service terminals, not the whole website-and-app list. That distinction matters when defining an audit, and it is why “transport website” is not a sufficient scope description on its own.
The underlying requirement is functional: this information and these functions need to be available through more than one sensory channel, presented so people can perceive and understand them, and usable by people with disabilities — including people using assistive technology at a kiosk or on a phone. For air travel, the Irish Aviation Authority (IAA) confirms this applies to any airline offering services departing from, transiting through, or arriving at an Irish airport — not only Irish-registered carriers.
WCAG is useful for evaluating in-scope website and app elements. It does not by itself cover a physical terminal, the wider service documentation or every sector-specific requirement, so an evaluation should name the mode, service category, journeys, interfaces and hardware actually included.
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. The NTA's own guidance explicitly names this as one of two available grounds for non-compliance for transport operators, so a small commercial bus operator or local waterborne service should check the numbers directly rather than assume the rules only apply to national carriers.
- Fundamental alteration or disproportionate burden is the second ground the NTA recognises, but only where it would fundamentally alter the nature of the service, or impose a disproportionate burden on the specific operator — assessed and documented, not asserted.
- Transitional rules can apply to existing service arrangements and equipment. Regulation 38 contains separate rules and dates for services using products already lawfully in use, existing service contracts and self-service terminals. Do not collapse those into one “2030 deadline”; record when each contract and terminal entered service and check the applicable rule.
- Products are not covered by the services exemption in the same way — a microenterprise operator that also manufactures or imports covered self-service hardware faces separate product obligations.
Which regulator enforces it, and what evidence they expect
The Irish government's EAA overview confirms the split: the Irish Aviation Authority is the compliance authority for the specified air-passenger elements, while the National Transport Authority is the authority for the specified bus, rail and waterborne elements. The same overview sets out the narrower scope for urban, suburban and regional services.
The NTA says a service provider that identifies non-conformity should notify it and describe the corrective measures. The IAA publishes the air-passenger elements it monitors and a complaint route. Useful evidence therefore starts with a mode-and-element inventory, the evaluation scope, findings and remediation records; any additional regulatory evidence should be confirmed with the relevant authority rather than inferred from a generic web-audit checklist.
An operator needs both authorities only if its activities actually cross their remits — for example, air passenger services as well as an NTA-regulated mode. Operating both bus and waterborne services does not by itself create an IAA remit.
A practical self-check before commissioning an evaluation
- Identify every mode and service category you operate, including whether a bus, rail or waterborne service is urban, suburban or regional. Map air elements to the IAA and the relevant bus, rail and waterborne elements to the NTA.
- Inventory only the elements the applicable category brings into scope — which may include a booking website or app, e-ticketing, transport information or specified self-service terminals. Do not assume the same list applies to every transport category.
- Record when existing service contracts, products and self-service terminals entered service, then check the separate Regulation 38 transitional rule that applies to each.
- Confirm the microenterprise test with real numbers — headcount and turnover or balance-sheet total — if you think it might apply to your operation.
- Decide, before requesting quotes, whether the evaluation needs to include physical kiosk/terminal testing alongside a web and app review — this materially changes scope and cost.
Our accessibility evaluation service scopes these questions with the client first, and states clearly what was and wasn't covered rather than implying a blanket compliance sign-off.
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
- National Transport Authority: European Accessibility Act for public transport in Ireland
- Irish Aviation Authority: Airline digital accessibility
- CCPC: European Accessibility Act guidelines for microenterprises
- W3C: Web Content Accessibility Guidelines 2.2
Read next
- European Accessibility Act in Ireland: full website guide 2026
- Does the EAA apply to my Irish e-commerce site?
- Does the EAA apply to my Irish consumer banking service?
- Accessibility audit service details
Need this checked properly?
Use the brief call to identify your mode(s), the regulator that applies, and the website, app and terminal scope an evaluation should cover. Implementation, once findings are in hand, is a separate step you can hand to your own developer or agency of choice.