Accessibility law for online businesses in Ireland: what the Accessibility Act, the Equal Status Acts and WCAG 2.1 AA ask of a shop, a SaaS product and a corporate site

The point: the Act is in force here, and one standard sits under all of it

The European Accessibility Act has applied since 28 June 2025.¹ It is no longer a deadline to prepare for. It is the law your shop or your software product is measured against today, in every EU country, and it names eCommerce services explicitly.¹ Ireland is in the EU, so there is no "does this reach us" question to ask. The Act is Irish law through the European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636 of 2023, in operation from that same day.² Germany enforces the Act through the Barrierefreiheitsstärkungsgesetz and Austria through the Barrierefreiheitsgesetz, both from the same date.³⁴ The UK next door is outside the Act, but the Equality Act 2010 has required reasonable adjustments from every service provider there, websites included, since 2010.⁵⁶

Underneath all of that sits one technical benchmark: the European standard EN 301 549, which for web pages is the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA.⁷ So the whole legal landscape, for a business that sells online, collapses into one practical question. Does the site meet WCAG 2.1 AA, and can you show it?

I go through the law at home in Ireland, in Germany and Austria where a good few Irish shops ship, and in the UK next door, then the four WCAG principles with one example each, what a checkout, a SaaS dashboard and a corporate site each get wrong, how a review runs, and a Cork retailer's checkout audit with findings and fixes. The business numbers are made up. The law and the footnoted figures are not.

What the European Accessibility Act requires, and from whom

The Act is Directive (EU) 2019/882. Member states had to pass their national laws by 28 June 2022 and apply them from 28 June 2025.¹ The services it covers are listed in article 2(2), and point (f) is eCommerce services.¹ Article 3(30) defines those broadly: services provided at a distance, through websites and mobile device based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract.¹ If a private individual can buy from you on a website or in an app, that is you.

The obligation itself is in article 13. Service providers must design and provide their services in accordance with the accessibility requirements, prepare the information set out in Annex V, and explain how the service meets the requirements.¹ The Act does not only ask you to be accessible. It asks you to be able to say how, in writing.

There are two escape hatches, and one of them is small. Article 4(5) exempts microenterprises providing services entirely.¹ A microenterprise employs fewer than 10 persons and has an annual turnover, or a balance sheet total, not exceeding €2 million.¹ Cross the headcount line and the exemption is gone. The second hatch is article 14: the requirements apply only where compliance does not fundamentally alter the service and does not impose a disproportionate burden, and you must carry out and document a self assessment to rely on it.¹ In my experience nobody running a normal online shop gets through that door. Labelling a form field is not a disproportionate burden.

The Act applies to anyone who provides the service on the Union market or offers to.¹ Where the company is registered does not come into it. A business in Galway that ships to customers in Munich is providing an eCommerce service on the Union market twice over: the Irish Regulations apply at home, and the German law applies to the German side of the trade the way German consumer law already does.

One more date gets misread constantly. Article 32 provides a transitional period to 28 June 2030, but it covers products that service providers were lawfully using before 2025 and service contracts signed before then.¹ It is not a grace period for your website.

Worked example: three businesses and whether the Act reaches them

An example, with three invented companies. Shandon Kitchenware in Cork sells cookware online, has 14 staff, and about a fifth of its orders go to Germany and Austria. It is an eCommerce service, over the headcount line, offered on the Union market. The Act applies at home through the Irish Regulations, in Germany and Austria through their laws, and the Equal Status Acts apply on top.

Corrib Clinic Software, a Galway SaaS company with six people, sells a scheduling tool to small clinics by subscription, including clinics in Vienna. Six people and a turnover well under the threshold makes it a microenterprise, so under article 4(5) it is exempt.¹ Two things still bite. The tenth hire ends the exemption. And its clinic customers are service providers under the Act themselves, and increasingly ask their software vendors to show WCAG conformance because they have to explain their own. In my experience the exemption protects you from the regulator and from nobody else.

Suir Valley Freight in Waterford has a corporate site with a contact form. No consumer buys anything there, so it is not an eCommerce service under article 3(30).¹ The Act does not reach it. The Equal Status Acts still do, which I come to below.

Ireland: the Regulations, the CCPC, the NDA, and the Equal Status Acts underneath

The Irish law is the European Union (Accessibility Requirements of Products and Services) Regulations 2023, made by the Minister for Children, Equality, Disability, Integration and Youth under the European Communities Act 1972, and in operation since 28 June 2025.² Regulation 3(2) lists the services it applies to, and point (g) is eCommerce services, defined in regulation 2 in the Directive's own words.² Regulation 14 is the obligation: a service provider shall ensure the service is designed and provided in accordance with the accessibility requirements, shall prepare the Schedule 3 information explaining how it meets them before providing the service, shall make that information available to the public in writing and orally, in a manner accessible to people with disabilities, and shall keep procedures in place so the service stays in conformity as it changes.² Fall out of conformity and regulation 14(4) asks for corrective measures and for the compliance authority to be told.²

The microenterprise exemption is regulation 5(4), which disapplies the service requirements and regulation 14 for a service provided by a microenterprise, defined exactly as in the Directive: fewer than 10 people and a turnover or balance sheet total not exceeding €2 million.² The disproportionate burden route is regulation 15, and it is paperwork heavy by design. You carry out an assessment against the criteria in Schedule 4, document it, keep the record for five years after the service was last provided, renew it whenever the service changes and at least every five years, and hand it over on request.² You cannot rely on it at all if you took outside funding to improve accessibility.²

Who checks. Regulation 4 names the Competition and Consumer Protection Commission as the market surveillance authority for products and as the compliance authority for eCommerce services and for e books.² The other services have their own: the Commission for Communications Regulation, Coimisiún na Meán, the Irish Aviation Authority, the National Transport Authority and the Central Bank of Ireland.² The CCPC says it will take a proportionate approach, aimed at helping businesses, above all microenterprises and SMEs, understand and comply.⁸ The National Disability Authority advises those authorities on the accessibility requirements, and its Centre for Excellence in Universal Design publishes the practical guidance, the definitions and the webinars.⁹ The CCPC worked with the NDA on guidelines specifically for microenterprises, consulted on them in April 2025, and set out how a business notifies non compliance or a claimed exemption.¹⁰ Anyone can complain to the relevant authority that a service is not in compliance, and regulation 41 obliges the authority to consider it.²

The teeth are in regulation 32. Providing a service that does not comply with regulation 5(1) is an offence, and so is failing to document or notify a disproportionate burden assessment or ignoring a direction.² On summary conviction that is a class A fine or up to six months in prison or both, and on indictment a fine of up to €60,000 or up to 18 months or both, with the court told to weigh the extent of the failure, the number of services affected and the number of people affected.² The number is lower than the German and Austrian ceilings, but note the word conviction. Germany's section 37 is a Bußgeld, an administrative fine.¹¹ Ireland's regulation 32 is a criminal offence tried in court.² Regulation 38 carries the same transition as the Directive, to 28 June 2030, for products a provider was already using and for service contracts agreed before 28 June 2025.² Not for your website.

Underneath the Regulations sits older law that reaches every service provider, including Suir Valley Freight's contact form. Section 5(1) of the Equal Status Act 2000 says a person shall not discriminate in disposing of goods to the public or in providing a service, whether for payment or not.¹² Section 4(1) says discrimination includes a refusal or failure by the provider of a service to do all that is reasonable to accommodate the needs of a person with a disability by providing special treatment or facilities, if without them it would be impossible or unduly difficult for the person to use the service.¹³ Section 4(2) sets the limit: a refusal is not deemed reasonable unless providing the accommodation would cost more than a nominal cost.¹³ The Acts, cited together as the Equal Status Acts 2000 to 2018, name no technical standard. The IHREC guide on the Acts spells out the duty in plain words, says the size and resources of the business and the actual cost decide what is nominal, recommends a published reasonable accommodation policy on the business's website in accessible formats, and explains the route for a complaint: notify the provider on Form ES.1 within two months, then the Workplace Relations Commission.¹⁴ For a software company, a name on a button is a nominal cost by any reading. Nominal is a lower bar than the UK's "reasonable", and it cuts the other way: there is less room to argue.

Public bodies have a third layer. The Disability Act 2005 requires each head of a public body to make access to its services integrated for people with and without disabilities where practicable, to appoint access officers, and to make electronic communications accessible to people with a visual impairment who have adaptive technology.¹⁵¹⁶ The NDA's Code of Practice on Accessibility of Public Services and Information provided by Public Bodies was declared an approved code under that Act in 2006, and it says itself that it is not a code of practice for the Equal Status Acts.¹⁷ Since 2020 the European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020 add the harmonised standard, EN 301 549, as the benchmark for the State, local authorities and bodies governed by public law.¹⁸ If you run a company, that third layer is not yours. The first two are.

An example: Corrib's Limerick competitor, Appointly, gets an email from a patient who uses a screen reader and cannot tell which of the twelve unlabelled icon buttons on the public booking page confirms the appointment. Under section 4 the question is not whether Appointly fixes it for her. It is whether a name on each button is more than a nominal cost to a software company, and it is not, so the failure to have done it is discrimination under the Acts, and under regulation 14 of the new Regulations it is also a service not provided in accordance with the requirements.¹³² That is the shape of nearly every accessibility complaint I have seen: not malice, just a thing nobody checked.

Germany and Austria: the same Act with a local name

Germany's law is the Barrierefreiheitsstärkungsgesetz, BFSG for short, passed on 16 July 2021 and applying from 28 June 2025.³ Section 1(3) lists the services in scope, and number 5 is Dienstleistungen im elektronischen Geschäftsverkehr, services in electronic commerce.³ Section 3(3) carries the microenterprise exemption for services, word for word the Directive's.¹⁹ The old version of this article put it the other way round, as the law applying to businesses with 10 or more employees or over €2 million turnover. That is the exemption read backwards: you are exempt only with fewer than 10 people and a turnover or balance sheet within €2 million. Section 37 sets fines of up to €100,000 for offering or providing a non compliant service, and up to €10,000 for lesser offences such as failing to provide the required information.¹¹ Section 38 carries the same transition for products and existing contracts, ending on 27 June 2030.²⁰

Austria's law is the Barrierefreiheitsgesetz, BaFG, published as BGBl. I Nr. 76/2023 and applying from 28 June 2025.⁴ The Sozialministerium's summary lists services in electronic commerce among the covered services, states that microenterprises offering services are exempt in full, names the Sozialministeriumservice in Linz as the market surveillance authority, and gives a maximum fine of €80,000 for large companies.⁴

The older Austrian law the previous version of this article leaned on, the Web Zugänglichkeits Gesetz, covers public sector websites and apps. It is not the one an Irish shop meets in Austria. The BaFG is.

The UK next door: the Equality Act, reasonable adjustments, and no named standard

Plenty of Irish shops sell into Northern Ireland and Britain, so the neighbour's rules are worth a page. The UK has no Accessibility Act. What it has is older and, in one way, broader.

Section 29 of the Equality Act 2010 says a service provider must not discriminate against a person requiring the service by not providing it, and subsection (7) applies the duty to make reasonable adjustments to every service provider.⁶ Section 20 sets out that duty: where a provision, criterion or practice, a physical feature, or the lack of an auxiliary aid puts a disabled person at a substantial disadvantage, the provider must take such steps as it is reasonable to have to take, and where information is involved that includes providing it in an accessible format.⁵

The Equality and Human Rights Commission's Code of Practice on services, updated in August 2026, states plainly that the service provisions apply to services provided on a website.²¹ It also makes the point most businesses miss. The duty is anticipatory: a service provider should not wait until a disabled person wants to use a service, but should anticipate what disabled people may need. It is owed to disabled people generally, not to the one person who complains, and it is a continuing duty.²¹ What counts as reasonable depends on effectiveness, practicability, cost, disruption, and the size and resources of the provider.²¹

The Equality Act names no technical standard, which is its broad part and its vague part at once. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 fill that gap, but only for the state, regional and local authorities, and bodies governed by public law.²² They require websites and apps to be perceivable, operable, understandable and robust,²² and the UK government's guidance says a public sector body meets them if it meets WCAG 2.2 AA.²³ The same guidance page says, in one line, that all UK service providers have a legal obligation to make reasonable adjustments under the Equality Act 2010.²³ If Shandon Kitchenware ships to Belfast or Liverpool, that line is its line there.

One standard underneath all of it: EN 301 549 and WCAG 2.1 AA

Every law above points at the same benchmark. Article 15 of the Act gives a presumption of conformity to products and services that meet harmonised standards.¹ The European standard for digital accessibility is EN 301 549, Accessibility requirements for ICT products and services, published jointly by CEN, CENELEC and ETSI. Version 3.2.1 was harmonised in August 2021 under the Web Accessibility Directive for the public sector, and the European Commission notes that it draws heavily from WCAG 2.1 while adding requirements for software, documents and hardware that WCAG does not cover.²⁴ The NDA's own guidance lists it as the standard being revised for the Act.⁹

The link to WCAG is written into the standard itself. Clause 9.0 says that conformance with WCAG 2.1 level AA is equivalent to conforming with all of clauses 9.1 to 9.4 and the conformance requirements of clause 9.6, which are the web clauses.⁷ For a website, meeting WCAG 2.1 AA is meeting the web part of the European standard.

Two honest caveats. First, the standards bodies revised EN 301 549 for the Accessibility Act, and the new version 4.1.1, which moves the web clauses to WCAG 2.2, was published in September 2026, but as of that month it had not yet been cited in the Official Journal under the Act.²⁵ Until a version is cited, the formal presumption of conformity is not there and the Act's requirements in Annex I, Schedule 1 in the Irish Regulations, apply directly.² Second, this is not a problem in practice, because W3C states that content conforming to WCAG 2.2 also conforms to WCAG 2.1 and 2.0.²⁶ Build to 2.1 AA today and you are on the path the next version takes.

This is why the only wording I will put in front of a client is "built to WCAG 2.1 AA, the standard the Accessibility Act relies on". Never "guaranteed compliant". Compliance with a law is a finding a court or the CCPC makes about your whole service. Conformance with a standard is something I can test, document and stand behind. I only make promises I can keep.

The four principles, one example each

WCAG 2.1 is built on four principles, and once you know them, every one of its success criteria falls into place.²⁷

Perceivable. Information and user interface components must be presentable to users in ways they can perceive.²⁷ The classic failure is a product photo with no text alternative, which criterion 1.1.1 requires.²⁷ For a cast iron pan, "cast iron casserole, 24 cm, matt black, lid on" does the job. "IMG_4471.jpg" does not, and neither does "image".

Operable. User interface components and navigation must be operable.²⁷ Criterion 2.1.1 requires that all functionality is operable through a keyboard, and 2.4.7 that the keyboard focus indicator is visible.²⁷ The failure I see most is a designer removing the focus outline because it looked untidy. A keyboard user then tabs through the page blind, with no idea what will activate when they press enter.

Understandable. Information and the operation of the user interface must be understandable.²⁷ Criterion 3.3.1 says that when an input error is detected, the item in error is identified and the error is described in text.²⁷ A red border alone is colour alone, which 1.4.1 forbids.²⁷ "Please check the form" identifies nothing. "Eircode: enter an Eircode such as T12 X70A" identifies the field and says how to fix it.

Robust. Content must be robust enough that it can be interpreted by a wide variety of user agents, including assistive technologies.²⁷ Criterion 4.1.2 requires that every user interface component has a name and role that can be programmatically determined.²⁷ A date picker built from styled div elements looks like a control and tells a screen reader nothing. A real button tells it "button, choose delivery date".

Worked example: is the grey text on Shandon's buttons readable

An example of the criterion that fails on more home pages than any other, contrast. Criterion 1.4.3 requires a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text, meaning at least 18 point, or 14 point bold.²⁷ The ratio is defined as:

$$CR = \frac{L_1 + 0.05}{L_2 + 0.05}$$

Here $CR$ is the contrast ratio, $L_1$ is the relative luminance of the lighter of the two colours and $L_2$ that of the darker, each between 0 for black and 1 for white, and the $0.05$ terms stand in for the light a screen reflects even when showing black.²⁷ It is a plain ratio of two quantities, the kind explained in Foundations: ratios and rates.

Shandon's secondary buttons carry mid grey text on white. White has a relative luminance of $1.0$. The grey, through WCAG's luminance formula, comes to $0.254$. So:

$$CR = \frac{1.0 + 0.05}{0.254 + 0.05} = \frac{1.05}{0.304} \approx 3.45$$

The result $3.45$ is below the $4.5$ that 14 pixel button text needs, so the buttons fail. The contrast ratio is a plain ratio of two numbers, the kind Foundations: ratios and rates explains. The designer's instinct is to make the text bold and call it large, but 14 pixel bold is not 14 point bold. The fix is a darker grey. One with a relative luminance of $0.100$ gives $1.05 / 0.150 = 7.0$, comfortably over the line, and to most eyes it reads as the same grey, only crisper. That is the pattern with most of WCAG: the fix is smaller than the fear.

What each kind of site gets wrong most often

WebAIM runs an automated check of one million home pages every year. The 2026 edition found detectable WCAG 2 failures on 95.9% of them, 56.1 errors per page on average, and six failure types account for 96% of all errors detected.²⁸

Each bar is one failure type, and its height is the share of the million home pages where an automated tool found at least one instance.²⁸ Low contrast text appears on more than four pages in five. Each of the six is, individually, minutes of work to fix. The takeaway is that the most common failures are the least expensive ones, so a first pass pays back fast.

In the audits I have done, each kind of site has its own habit on top of those six.

An eCommerce checkout most often fails on forms and on what happens after a mistake. Address fields with placeholder text instead of labels, so the hint vanishes as soon as you type. Errors shown by colour alone. A delivery option carousel that cannot be reached with a keyboard. A third party payment iframe nobody tested with a screen reader because it was "the provider's problem", when regulation 14 makes the service as a whole yours.² And a basket that expires during a slow screen reader session with no warning and no way to extend, which criterion 2.2.1 requires.²⁷

A SaaS dashboard most often fails on custom controls and on data. Toggles, dropdowns, modals and tabs built from div elements with click handlers, so they have no name, role or state. Charts that exist only as pixels, with no table behind them. Keyboard traps inside a modal. Icon only buttons, dozens of them, with no accessible name, exactly the booking page from the Limerick example.

A corporate site fails more quietly. PDFs with no tags, so a screen reader gets one unstructured block or nothing. Videos without captions. A cookie banner that cannot be dismissed with a keyboard, which traps the whole site behind it. Heading levels used for size rather than structure, so the outline a screen reader user navigates by is nonsense. And grey on grey, because it looked elegant in the mock up.

How a review runs, top to bottom

Here is the sequence I follow. It matters that the automated step comes early and is not the last step.

The honest limit of the automated step deserves its own paragraph, because vendors sell it as the whole job. In 2017 the UK Government Digital Service built a page with 143 deliberate accessibility barriers and ran 10 free automated tools over it. The best tool found 37% of the barriers, 41% counting its prompts for manual inspection, the most popular found 17%, and 42 of the 143 were missed by every tool.²⁹ Deque, which makes the axe tools, published its own study in 2021 of over 2,000 audits and nearly 300,000 issues and reported that automated testing completely covered 57% of issues, against what it called the widely accepted belief of 20% to 30%.³⁰ That figure comes from the vendor and counts issues rather than kinds of barrier, so a page with 40 missing alt texts helps the percentage along. WebAIM itself says that all automated tools, including WAVE, have limitations and not all conformance failures can be automatically detected.²⁸

My own experience sits between those numbers. The scanner finds most of the volume and almost none of what stops someone finishing a purchase. No scanner has ever told me that a payment iframe swallows keyboard focus, or that the "continue" button is announced as "button" and nothing else. Those come from the keyboard and screen reader passes, which take an afternoon per journey and are where the money is.

Worked example: the Shandon Kitchenware checkout audit, nine findings and their fixes

An example, worked through end to end. Shandon Kitchenware in Cork, 14 staff, around 1,800 orders a month, a four step checkout: basket, delivery, payment, confirmation. I scope the four steps plus sign in, run the scan, then do the keyboard and screen reader passes on each. The findings, with severity, the criterion failed, and the fix.

Blocking. The card fields live in a third party iframe that takes focus on load and never gives it back, so a keyboard user cannot reach the "pay now" button. Criterion 2.1.2, no keyboard trap.²⁷ Fix: configure the provider's embed so focus stays in document order. Two hours with the provider's documentation.

Blocking. Address fields have placeholders and no labels. A screen reader user tabbing into "Address line 1" hears "edit text" and nothing else, and once anyone types, the sighted user loses the hint too. Criteria 3.3.2, labels or instructions, and 1.3.1, info and relationships.²⁷ Fix: real label elements, visibly above each field, Eircode included. One hour.

Blocking. Errors on the delivery step are shown by a red border only, and the page scrolls back to the top. Criteria 3.3.1, error identification, and 1.4.1, use of colour.²⁷ Fix: a text message beside each failed field saying what is wrong and how to correct it, plus an error summary at the top that receives focus. Three hours.

Serious. The delivery slot picker is a carousel of div elements with click handlers: no role, no name, no keyboard support. Criteria 4.1.2 and 2.1.1.²⁷ Fix: rebuild as a group of radio buttons, styled to look identical. Half a day.

Serious. Secondary button text at 3.45:1 on white, the example above. Criterion 1.4.3.²⁷ Fix: one token change in the design system. Fifteen minutes, and it fixes 40 pages at once.

Serious. The basket expires after 15 minutes of inactivity with no warning, and a screen reader user filling in an address takes longer than that. Criterion 2.2.1, timing adjustable.²⁷ Fix: a warning two minutes before expiry with a one click extend. Two hours.

Moderate. Product images in the basket summary have empty alt text, so a screen reader user cannot confirm what they are buying. Criterion 1.1.1.²⁷ Fix: pass the product name through as the alt text. One hour.

Moderate. Focus outline removed globally in the stylesheet. Criterion 2.4.7.²⁷ Fix: delete one CSS rule and design a focus ring in the brand colour. One hour.

Minor. The page language attribute is missing on the German version of the checkout, so a screen reader reads German text with English pronunciation. Criterion 3.1.1.²⁷ Fix: set the attribute per locale. Fifteen minutes.

Each bar is one of the four principles and its height is how many of the nine findings fall under it. The spread is typical of a checkout: perceivable and operable carry most of it, because forms and custom controls are where shops build things themselves. The total fix effort is about three working days. The three blocking findings, which stop a real person paying, are six hours. Against 1,800 orders a month, a checkout some customers cannot finish is not a compliance line item. It is revenue walking out, which is the next section.

Why accessibility is also a growth lever

The sourced figures first, my own view second.

Census 2022 counted 1,109,557 people in Ireland, 22% of the population, who reported experiencing at least one long lasting condition or difficulty to any extent, and 407,342 of them, 8% of the population, who experience one to a great extent or a lot.³¹ That is more than one customer in five. The spending figures I can source are British, and I name them as such. Scope puts the number of disabled people in the UK at 16 million, from the government's Family Resources Survey, and estimates the spending power of households with at least one disabled person at 274 billion pounds sterling a year.³² The Click Away Pound Survey of 2019, a British study by the disability consultancy Freeney Williams with its figures in pounds, found that 69% of disabled online consumers with access needs click away from a website they find difficult to use, that 83% limit their shopping to sites they know are accessible, that 86% have paid more for a product from an accessible website rather than buy it for less from one that was harder to use, and that only 8% of those who hit a problem ever contact the site owner.³³ I know of no Irish survey of that depth. I also know of no reason a shopper in Cork would behave differently from one in Cardiff.

The survey's headline figure, 17.1 billion pounds a year in lost UK online sales, is a simple calculation, and it is worth seeing how it is built so you can judge it:

$$\text{lost spend} = N \times s \times \bar{x}$$

Here $N$ is the number of disabled internet users with access needs, $s$ is the share of them who click away, and $\bar{x}$ is the mean online spend per internet user per year. The survey took $N = 7.15$ million (71% of the 10.07 million disabled adults the ONS counted as active internet users), $s = 0.69$, and $\bar{x} = 3{,}460$ pounds (the 2018 UK online retail spend divided by the number of adults with internet access).³³ So $7.15 \times 0.69 \approx 4.93$ million people, and $4.93$ million times $3{,}460$ pounds is about $17.1$ billion pounds. The mean is the lever here (see Foundations: the mean), and it assumes disabled shoppers spend the national average per head, which the survey itself calls an estimate. Take it as the order of magnitude, not the decimal place. Scale it to Ireland by population and the shape of the argument does not change.

Now my view. The 8% figure is the one I would pin above the desk. For every customer who tells you the checkout did not work for them, roughly eleven said nothing and bought elsewhere. Your analytics shows them as a drop off on the payment step, indistinguishable from someone who changed their mind. In the shops I have worked on, accessibility fixes have moved the checkout completion rate for everyone, because a labelled field, a clear error message and a button that says what it does help a tired person on a phone on the Cork to Dublin train just as much. The same work gives you alt text that search engines read, a keyboard operable interface that automated tests can drive, and semantic markup that costs less to maintain. I have never seen an accessibility fix make a site worse for the sighted mouse user. I have seen plenty quietly lift conversion.

There is also the procurement point from the Corrib example. A clinic, a county council or a larger company that has to explain its own compliance under regulation 14 will ask its vendors to show theirs.² A SaaS product with a WCAG 2.1 AA conformance record wins tenders that a better product without one is excluded from before anyone reads the features. Public bodies in Ireland have had their own accessibility duties since 2005, so they have been asking for longer than most.¹⁵

What I would do, in order

Write down the scope: the templates and the journeys. Run the scan and fix the six common failures across the whole site, because they are the least expensive and the most visible. Do the keyboard and screen reader passes on the journeys that make money, and fix anything that blocks one before anything else. Write the conformance record against WCAG 2.1 AA and the Schedule 3 information the Regulations ask for, in an accessibility statement that admits what is not done yet and says when.² Put the automated check in the deployment pipeline so it cannot regress, and make the manual passes part of the release checklist for anything that touches a form or a control, the way I treat every other release gate.

Then say, in public, exactly what is true: built to WCAG 2.1 AA, the standard the Accessibility Act relies on. Not a word more. The work will say the rest.

Sources

Footnotes

1. European Parliament and Council, Directive (EU) 2019/882 of 17 April 2019 on the accessibility requirements for products and services (European Accessibility Act), articles 2, 3, 4, 13, 14, 15, 31 and 32, EUR Lex, 2019, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882

2. Minister for Children, Equality, Disability, Integration and Youth, S.I. No. 636/2023, European Union (Accessibility Requirements of Products and Services) Regulations 2023, regulations 1 to 5, 14, 15, 32, 38 and 41, electronic Irish Statute Book, 2023, https://www.irishstatutebook.ie/eli/2023/si/636/made/en/print

3. Bundesministerium der Justiz, Barrierefreiheitsstärkungsgesetz (BFSG), § 1 and the note on entry into force, gesetze im internet, 2021, https://www.gesetze-im-internet.de/bfsg/BJNR297010021.html

4. Bundesministerium für Soziales, Gesundheit, Pflege und Konsumentenschutz, Barrierefreiheitsgesetz (BaFG), BGBl. I Nr. 76/2023, sozialministerium.gv.at, https://www.sozialministerium.gv.at/Themen/Soziales/Menschen-mit-Behinderungen/Barrierefreiheitsgesetz.html

5. UK Parliament, Equality Act 2010, section 20, Duty to make adjustments, legislation.gov.uk, https://www.legislation.gov.uk/ukpga/2010/15/section/20

6. UK Parliament, Equality Act 2010, section 29, Provision of services, etc., legislation.gov.uk, https://www.legislation.gov.uk/ukpga/2010/15/section/29

7. CEN, CENELEC and ETSI, EN 301 549 V3.2.1 (2021 03), Harmonised European Standard, Accessibility requirements for ICT products and services, clause 9.0, ETSI, 2021, https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf

8. Competition and Consumer Protection Commission, CCPC role and responsibilities, Accessibility for businesses, ccpc.ie, 2025, https://www.ccpc.ie/enforcement-and-regulation/market-surveillance/accessibility/accessibility-for-businesses/ccpc-role-and-responsibilities

9. National Disability Authority, Centre for Excellence in Universal Design, European Accessibility Act, universaldesign.ie, 2025, https://universaldesign.ie/communications-digital/european-accessibility-act

10. Competition and Consumer Protection Commission, European Accessibility Act becomes law in Ireland on 28 June 2025, press release, 26 June 2025, https://www.ccpc.ie/news-and-media/news/article/2025/06/26/european-accessibility-act-becomes-law-in-ireland-on-28-june-2025

11. Bundesministerium der Justiz, Barrierefreiheitsstärkungsgesetz (BFSG), § 37 Bußgeldvorschriften, gesetze im internet, https://www.gesetze-im-internet.de/bfsg/__37.html

12. Oireachtas, Equal Status Act 2000, section 5, Disposal of goods and provision of services, electronic Irish Statute Book, https://www.irishstatutebook.ie/eli/2000/act/8/section/5/enacted/en/html

13. Oireachtas, Equal Status Act 2000, section 4, Discrimination on ground of disability, electronic Irish Statute Book, https://www.irishstatutebook.ie/eli/2000/act/8/section/4/enacted/en/html

14. Irish Human Rights and Equality Commission, Your Rights: Disability Rights, Equal Status Acts and Reasonable Accommodation, ihrec.ie, 2023, https://www.ihrec.ie/app/uploads/2023/11/3.-ESA-Reasonable-Accommodation.pdf

15. Oireachtas, Disability Act 2005, section 26, Access to services etc. provided by public bodies, electronic Irish Statute Book, https://www.irishstatutebook.ie/eli/2005/act/14/section/26/enacted/en/html

16. Oireachtas, Disability Act 2005, section 28, Access to information, electronic Irish Statute Book, https://www.irishstatutebook.ie/eli/2005/act/14/section/28/enacted/en/html

17. Minister for Justice, Equality and Law Reform, S.I. No. 163/2006, Disability Act 2005 (Code of Practice) (Declaration) Order 2006, with the National Disability Authority's Code of Practice on Accessibility of Public Services and Information provided by Public Bodies, electronic Irish Statute Book, 2006, https://www.irishstatutebook.ie/eli/2006/si/163/made/en/print

18. Minister for Communications, Climate Action and Environment, S.I. No. 358/2020, European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020, electronic Irish Statute Book, 2020, https://www.irishstatutebook.ie/eli/2020/si/358/made/en/print

19. Bundesministerium der Justiz, Barrierefreiheitsstärkungsgesetz (BFSG), § 3 Barrierefreiheit, Verordnungsermächtigung, gesetze im internet, https://www.gesetze-im-internet.de/bfsg/__3.html

20. Bundesministerium der Justiz, Barrierefreiheitsstärkungsgesetz (BFSG), § 38 Übergangsbestimmungen, gesetze im internet, https://www.gesetze-im-internet.de/bfsg/__38.html

21. Equality and Human Rights Commission, Equality Act 2010 Code of Practice for Services, Public Functions and Associations, paragraphs 3.6, 7.20 to 7.25, 7.32 and 7.36 to 7.40, GOV.UK, updated 5 August 2026, https://www.gov.uk/government/publications/equality-act-2010-draft-code-of-practice-for-services-public-functions-and-associations-2026/equality-act-2010-draft-code-of-practice-for-services-public-functions-and-associations-2026

22. UK Government, The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, SI 2018/952, regulation 3, legislation.gov.uk, 2018, https://www.legislation.gov.uk/uksi/2018/952/regulation/3/made

23. Government Digital Service, Understanding accessibility requirements for public sector bodies, GOV.UK, updated 30 September 2024, https://www.gov.uk/guidance/accessibility-requirements-for-public-sector-websites-and-apps

24. European Commission, Web Accessibility Directive, standards and harmonisation, Shaping Europe's digital future, updated 5 May 2025, https://digital-strategy.ec.europa.eu/en/policies/web-accessibility-directive-standards-and-harmonisation

25. Davis Wright Tremaine LLP, European Accessibility Act: ICT standards update (EN 301 549 V4.1.1), 18 September 2026, https://www.dwt.com/insights/2026/09/european-accessibility-act-ict-standards-update

26. W3C Web Accessibility Initiative, WCAG 2 Overview, W3C, updated 17 September 2026, https://www.w3.org/WAI/standards-guidelines/wcag/

27. W3C, Web Content Accessibility Guidelines (WCAG) 2.1, W3C Recommendation, 5 June 2018, updated 6 May 2025, https://www.w3.org/TR/WCAG21/

28. WebAIM, The WebAIM Million: an annual accessibility analysis of the top 1,000,000 home pages, 2026 edition, Utah State University, updated 30 March 2026, https://webaim.org/projects/million/

29. Mehmet Duran, What we found when we tested tools on the world's least accessible webpage, Accessibility in government blog, Government Digital Service, 24 February 2017, https://accessibility.blog.gov.uk/2017/02/24/what-we-found-when-we-tested-tools-on-the-worlds-least-accessible-webpage/

30. Deque Systems, Automated testing study identifies 57% of digital accessibility issues, Deque blog, 10 March 2021, https://www.deque.com/blog/automated-testing-study-identifies-57-percent-of-digital-accessibility-issues/

31. Central Statistics Office, Census of Population 2022 Profile 4, Disability, Health and Carers, Disability, cso.ie, 2023, https://www.cso.ie/en/releasesandpublications/ep/p-cpp4/censusofpopulation2022profile4-disabilityhealthandcarers/disability/

32. Scope, Disability facts and figures, citing the Family Resources Survey 2021 to 2022, scope.org.uk, https://www.scope.org.uk/media/disability-facts-figures

33. Freeney Williams and Click Away Surveys (Rick Williams and Steve Brownlow), Press release: Click Away Pound 2019, UK retailers lose out on 17 billion pounds by ignoring needs of disabled shoppers online, 6 February 2020, https://www.clickawaypound.com/downloads/CAP2019PR2.pdf