The European Accessibility Act (EAA), which was implemented into Irish law under the European Union (Accessibility Requirements of Products and Services) Regulations 2023, comes into effect on 28 June 2025.

These Regulations introduce accessibility requirements for certain products and services in the private sector, to enhance the ability of people with disabilities to use everyday products and services.

Key sectors such as e-commerce, banking, telecommunications, and transport are likely to feel the most impact.

In-scope businesses need to use the lead-in time to identify whether any of their products or services are within the scope of the Regulations and what they need to do to comply with the accessibility requirements under the EAA.

What Does the EAA Cover?

The EAA is not a general accessibility law and only applies to certain specified products and services.

Products covered by the EAA include:

■ Computers, laptops, and operating systems

■ ATMs, ticketing machines, and check-in kiosks

■ Smartphones, and other telecommunications devices

■ E-readers Services covered include:

■ E-commerce

■ Consumer banking

■ E-books and reading software

■ Access to audiovisual media services

■ Electronic communications services

■ Certain aspects of passenger transport services (air, bus, rail, and waterborne)

Key Requirements

The EAA outlines general accessibility standards for all products and services within its scope with additional requirements for specific products and services.

For products, businesses must:

■ Design products to maximise usability for individuals with disabilities

■ Provide accessible instructions for use and maintenance

■ Ensure packaging and support services are accessible

For services, requirements include:

■ Ensuring websites and mobile apps are accessible

■ Providing information on service features in accessible formats

■ Offering customer support systems that cater to people with disabilities

These standards aim to improve usability and foster inclusivity across the EU.

Accessibility Statements Businesses offering in-scope services must publish information about the accessibility of their services in their terms and conditions or equivalent

document, which is often done through an accessibility statement.

This document should:

■ Outline how the business complies with the EAA’s requirements

■ Be included in general terms and conditions or similar materials

■ Be available in accessible formats, such as written and oral versions

Accessibility statements are a key compliance tool and demonstrate a business’s commitment to inclusivity.

Preparing for Compliance

Preparing for the EAA involves assessing current practices and implementing changes to meet the new

standards.

Here are the steps businesses should take:

■ Assess scope: Identify whether your products or services fall under the EAA’s remit.

■ Understand your role: Determine the role you play in the supply chain of the specific product or services.  The requirements that the EAA imposes on business differ, depending on whether a business is a manufacturer, distributor, importer, authorised representative, or service provider.

■ Consider exemptions and transitional measures: In line with the EU law principle of proportionality, there are exemptions from some or all of the requirements of the EAA in addition to transitional measures which permit a grace period following the coming into force of the EAA.

Given the significant impact the EAA can have on businesses, it may be important to consider whether any of these can be relied upon to ease the transition to more accessible products or services.

■ Analyse requirements: Familiarise yourself with the accessibility requirements that apply to your products or services.

■ Conduct a Gap Assessment: Identify gaps in your current offerings and plan the changes needed to meet EAA standards.

■ Develop an Accessibility Statement if providing in-scope services

■ Train your design teams

■ Monitor and update: Regularly review your products, services, and processes to ensure ongoing compliance.

Conclusion

The European Accessibility Act will have significant consequences for Irish businesses subject to its

requirements. Given that there is now only six months before the European Accessibility Act takes effect in Ireland and that any changes required to product and services might be significant, now is an opportune time to progress your products and services towards compliance.

Dermot McGirr is a Commercial partner at Mason Hayes & Curran. For more information and expert advice on the EAA, visit MHC.ie/EAA