What an Irish online shop's accessibility statement must say, and who does not need one

The duty comes from the Irish rules that put the European Accessibility Act, Directive (EU) 2019/882, into law: S.I. No. 636 of 2023, the European Union (Accessibility Requirements of Products and Services) Regulations 2023, at Regulation 14(2). They came into operation on 28 June 2025 (Regulation 1(2)). They apply to services provided to consumers on or after that date (Regulation 3(2)), subject to the transitional rules in Regulation 38.

A microenterprise is exempt. Regulation 5(4) says that paragraph (3) and Regulation 14 shall not apply to a service provided by a microenterprise. Those two are the sources of a service's information duties. Regulation 14 holds the Schedule 3 information. Paragraph (3) brings in Schedule 1, which has its own information requirements in Part 3(b) and Part 4(g)(i). A microenterprise running an online shop therefore owes no accessibility information for the shop under these Regulations. The Competition and Consumer Protection Commission (CCPC) says the same in its guidelines for microenterprises.

Regulation 2(1) defines a microenterprise as “an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million”. Both halves must be met. On the money half, either figure is enough on its own: a business with nine people, €3 million of turnover and a balance sheet total of €1.5 million is a microenterprise. A headcount of ten or more fails the test whatever the turnover.

The Irish definition does not say how to count, and does not mention Commission Recommendation 2003/361/EC. The Directive does, in recital 53: for microenterprises to benefit from the Directive, they must truly meet the Recommendation's requirements and the case law aimed at stopping those requirements being got round. That is how the Directive means the definition to be read, though the Irish Regulations do not adopt the Recommendation in so many words. The Recommendation's counting rules are these. Headcount is counted in annual work units (full-time equivalents over the year), and owner-managers count. Figures come from the latest approved accounts, with turnover net of VAT. A partner enterprise's figures are added in proportion to the holding, and a linked enterprise's in full. Status changes only after a ceiling is crossed in two consecutive accounting periods.

Two more points settle the scope. First, the Regulations reach services provided to consumers. Regulation 2(1) defines e-commerce services as 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. A shop that sells only to businesses is outside them. Second, the microenterprise exemption covers services only. The CCPC lists six groups of in-scope products, among them home routers and e-readers, and says that microenterprises dealing with products must apply the accessibility requirements too. The piece on where the exemption stops sets out those duties.

The duty sits with the service provider. Regulation 2(1) defines that as any person who provides a service on the Union market, or makes offers to provide such a service to consumers in the Union. The Regulations say nothing about a hosted platform a shop is built on, and we found no Irish guidance dividing the duty between a shop and its platform. On a plain reading of the definition, the shop that offers to sell to consumers is the service provider, whichever platform it runs on. Nothing in the Regulations moves any part of the duty to the platform.

Two transitional rules in Regulation 38 matter here. The one for products, Regulation 38(1)(a), runs to 28 June 2030 but does not cover a website: the CCPC says products there means tangible items, not websites or mobile apps. The one for services, Regulation 38(1)(b), lets a service contract agreed before 28 June 2025 continue unchanged until it expires, but for no longer than five years from that date, which is 28 June 2030. The CCPC says it applies to contracts for in-scope services provided to consumers. It covers a contract already running, on its existing terms. It does not cover the shop as offered to anyone else: the CCPC says that from 28 June 2025 all new contracts for products and services covered by the Act must comply.

For a shop that is not a microenterprise, Regulation 14(2) requires the information set out in Schedule 3 to be prepared before the service is provided. It must be made public in writing and in oral (spoken) format, in an accessible way, and kept for as long as the service runs. The Directive sets the same duty in Article 13(2) and Annex V, and Schedule 3 copies Annex V with Irish cross-references.

The law's word is information, not statement. Schedule 3 says it goes in the general terms and conditions, or an equivalent document. It comes on top of the consumer information requirements of Directive 2011/83/EU on consumer rights. The law does not define an equivalent document. The cautious course is to put the information in the terms themselves. The other course is a separate page that the terms expressly incorporate, and we found no Irish guidance on it.

Schedule 3 does not deal with a shop's app separately. The information covers the whole service, app included, and goes where paragraph 1(a) puts it, in the terms or an equivalent document. Schedule 3 names no place inside the app. The public sector rules do name one: Regulation 7(3)(c) of S.I. No. 358 of 2020 puts a public body's app statement on its website or alongside the information available when downloading the app. Nothing in S.I. 636 says the same for a shop.

The accessibility requirements that apply to a shop are in Schedule 1: Part 3, the general requirements for services, and Part 4(g), which is specific to e-commerce. Part 4(g)(i) adds an information duty of its own, outside Schedule 3. A shop must provide the accessibility information for the products and services it sells, when the responsible economic operator provides it. If the manufacturer, the importer or another responsible economic operator provides accessibility information for a product you sell, make it available to customers where the product is offered, for example on its product page.

Schedule 3 sets out what to say, not how to lay it out, and none of the CCPC's pages for businesses that we read publishes a template. The table below gives each heading with the provision behind it. Schedule 3 does not require the last three, and the table says why each is there.

Describe what is true of the site on the day it is published, in detail a customer can check. Some content is outside the Regulations under Regulation 3(4), such as third-party content you neither fund, develop nor control. Name it under the fourth heading.

Name a standard only if you tested against it. Schedule 3 paragraph 2 lets a provider apply harmonised standards and technical specifications whose references have been published in the Official Journal. A service that meets them is presumed to conform (Regulation 16). As of 16 October 2026, no harmonised standard has been cited under the Accessibility Act, Directive (EU) 2019/882. The European Commission's list of harmonised standards has one accessibility entry, and it is for websites and mobile applications of public sector bodies under Directive (EU) 2016/2102. We found no technical specification adopted under the Act either. For now, testing against a standard is evidence, not a presumption, and compliance is judged against Schedule 1 itself.

The National Disability Authority (NDA) says EN 301 549 V4.1.1 was published on 2 September 2026 and is built on WCAG 2.2. It says the standard is expected to be cited in the Official Journal on 16 December 2026, and becomes legally binding, with a presumption of conformity, only once cited. Until then, it says, V3.2.1, built on WCAG 2.1, remains the standard in force. The piece on WCAG AA covers what that changes for a website.

Regulation 14(2)(b) requires the information in writing and in oral format, including in a manner that is accessible to persons with disabilities. The CCPC's page for businesses describes this as written and spoken formats, fully accessible. Neither the Regulations nor the CCPC's pages say what counts as the oral (spoken) version, and we found no Irish decision on it.

For the written version, the obvious form is a web page built to the same standard as the rest of the site, with real headings and text that enlarges and reflows. The CCPC's guidelines for microenterprises list, as a common issue, information provided in only one format, such as a PDF that has not been made accessible.

Here are two ways to provide the spoken version, offered only as suggestions: a recording of the page read aloud, or a named phone number where somebody will read it out on request. We found no published decision that has considered either. Schedule 1, Part 3(b)(i) points the same way: it requires information about how the service functions to be available via more than one sensory channel.

The only accessibility statement template from an Irish authority that we found is the public sector one. S.I. No. 358 of 2020 requires public sector bodies to publish a statement on the website concerned, using the model in Commission Implementing Decision (EU) 2018/1523. The Centre for Excellence in Universal Design, part of the National Disability Authority, publishes guidance on writing it for public sector bodies. The model's mandatory sections are a compliance status (fully, partially or not compliant), the content that is not accessible and why, the date and method of preparation, feedback and contact details, and the enforcement procedure. Regulation 7(4) of S.I. 358 adds a link to the redress provisions of the Equal Status Act 2000 and the Disability Act 2005.

Copied onto a shop, it cites the wrong law and the wrong route to redress. It leaves out parts of what Schedule 3 asks for, such as how the service operates and how its delivery and monitoring keep it compliant. And its lines on failures and disproportionate burden work differently under the Accessibility Act.

Regulation 15(1) says the accessibility requirements apply only to the extent that meeting them does not require a significant change that fundamentally alters the basic nature of the service, or put a disproportionate burden on the operator. The words “to the extent” matter: the relief covers only the requirement, or the part of it, that would cause the change or the burden. For disproportionate burden, recital 66 of the Directive adds three points. Requirements not found to cause the burden should apply in full. The exception should go no further than strictly necessary. And lack of priority, time or knowledge should not be considered legitimate reasons.

Neither exception can simply be claimed. You can rely on one only after carrying out an assessment that finds compliance would cause the change or the burden (Regulation 15(2)). For burden, Regulation 15(3) and Schedule 4 make the assessment a costing exercise. Net compliance costs, built from named one-off and ongoing costs, are set against the overall costs of providing the service and against net turnover. They are weighed against the estimated benefit to persons with disabilities, taking into account the amount and frequency of use.

The assessment must be documented, a written record of its results kept for five years after the service was last provided, and a copy given to the CCPC on request (Regulation 15(4)). A burden assessment must be renewed when the service is altered, when the CCPC asks, and in any event at least every five years (Regulation 15(7)). The CCPC must be told that you are relying on the exception (Regulation 15(9)). Failing to comply with Regulation 15(4) or (9) is an offence under Regulation 32(1).

An operator that receives outside funding, public or private, to improve accessibility cannot claim the burden exception (Regulation 15(8)). The CCPC must check that the assessment was carried out and review it, including whether the Schedule 4 criteria were used correctly (Regulation 24(2)).

The CCPC's notification form has an option for a claimed exemption, asks whether the Regulation 15 assessment has been carried out, and says the assessment is mandatory and shall be provided to the CCPC on request.

Regulation 4(2)(g) makes the CCPC the compliance authority for e-commerce services. Under Regulation 24 it checks compliance, follows up complaints, and where a service does not comply gives the operator a direction to take corrective action. The procedure and the appeal are in the piece on whether the Act reaches your website.

Consumers report problems through the CCPC's accessibility complaint form, which lists e-commerce service as a category. The form says the CCPC is not an ombudsman and cannot act for a consumer in a dispute with a business. The CCPC's 2025 annual report says it received 53 complaints and 16 claimed exemptions under the Act in 2025, which are being actioned, with results expected in 2026. The CCPC says it will take a proportionate approach, and aims to help enterprises, particularly microenterprises and SMEs, understand and comply with their obligations.

A consumer does not need the CCPC to act. Under Regulation 30, a consumer who believes an operator has failed, or is failing, to comply with one or more requirements of the Regulations may apply to the Circuit Court. They apply in the circuit where they ordinarily live or carry on business, on notice to the operator and the CCPC. A consumer outside the State applies to the Dublin Circuit (Regulation 30(5)). A public body, or an organisation with a legitimate interest in compliance, may act on the consumer's behalf or in support, with the consumer's approval (Regulation 30(10)). The court can declare a failure, order compliance in the manner and period it specifies, and impose conditions. If it decides during the hearing that the case is not appropriate for it, it can transfer the case to the High Court.

Some failures are offences in themselves, listed in Regulation 32(1). They include Regulation 5(1), the duty to provide only services that meet the accessibility requirements, and Regulation 15(4) and (9). Regulation 14 is not on that list. A missing statement can reach a shop through a CCPC direction: not complying with it in the period set is an offence (Regulation 32(3)(a)). It can also reach a shop through Regulation 30, where failing without reasonable excuse to comply with the court's order is an offence (Regulation 32(3)(b)). A shop with no accessibility information may also be failing the information requirements in Schedule 1, Part 3(b) and Part 4(g)(i). Those sit under Regulation 5, and so under Regulation 32(1). We found no decision on whether a missing statement counts as that.

It is also an offence to give the CCPC information, in purported compliance with the Regulations, that you know or ought reasonably to know is false or misleading in a material respect (Regulation 32(5)). That covers what you put on the notification form.

Regulation 32(6) sets the penalties. On summary conviction: a class A fine (up to €5,000 under section 3 of the Fines Act 2010), up to 6 months' imprisonment, or both. On indictment: a fine of up to €60,000, up to 18 months' imprisonment, or both. Under Regulation 33, a director, manager, secretary or other officer can also be liable if they consented to, connived at or approved the offence, or if it is attributable to their wilful neglect. Regulation 34 gives a defence to any offence under the Regulations: proof that the person charged exercised due diligence and took all reasonable precautions to avoid committing it.

Start with the exemption, because it decides whether you owe any of the rest.