Empowering accessibility

Background

The European Union (EU) has taken a significant step towards inclusivity with the introduction of the European Accessibility Act (EAA). This directive aims to ensure that products and services across the EU are accessible to people with disabilities, promoting equal opportunities and participation in society.

The EAA is the result of the ratification by EU Member States of the United Nations Convention on the Rights of Persons with Disabilities. The EAA works in harmony with other EU legislation including the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive, positioning disability inclusion as a core component of Environmental, Social and Governance standards.

In Ireland, the EAA has been transposed by the European Union (Accessibility Requirements of Products and Services) Regulations 2023.

Scope

The EAA applies to a broad range of economic operators in the public and private sector. In relation to a product, this includes manufacturers, importers, distributors and authorised representatives. In relation to services, it means a service provider. It covers various sectors, including technology, banking, transport, and media.

The Act, and by extension the Regulations, will come into effect from 28 June 2025. Existing services and contracts will have until June 2030 to comply with the new requirements.

Key requirements

The EAA applies to products and services identified as being important for individuals with disabilities. Digital technologies are the main area of focus of the EAA and the regulations. The following are the accessibility requirements outlined in the EAA:

Design and functionality: Products and services must be designed to be accessible, meaning they should be usable by people with various disabilities. This includes features like accessible interfaces, clear instructions, and compatibility with assistive technologies.
Information accessibility: Information about the product or service, including instructions and accessibility features, must be provided in accessible formats. This ensures that all users can understand how to use the product or service effectively.
User interaction: The way users interact with products and services should be accessible. This includes ensuring that websites, software, and digital interfaces are navigable and usable by people with disabilities.
Customer support: Support services, including help desks and customer service, must be accessible. This means providing multiple ways for users to get help, such as through accessible websites, phone services, and in-person assistance.
Compatibility: Products and services should be compatible with assistive technologies, such as screen readers, hearing aids, and other devices that help people with disabilities use them.

Implementation in Ireland

The Act has been incorporated into Irish law through SI No. 636/2023, known as the European Union (Accessibility Requirements of Products and Services) Regulations 2023 (Irish Regulations). Schedule 1 of the Irish Regulations specifies both general and specific accessibility requirements for relevant products and services.

Products

The Regulations apply to the following products placed on the market on or after 28 June 2025:

consumer general purpose computer hardware systems and their operating systems;
payment terminals;
self-service terminals such as ATMs, ticketing machines, check-in machines and interactive self-service terminals providing information;
consumer terminal equipment with interactive computing capability, used for electronic communications services or for accessing audiovisual media services (e.g. smartphones); and
e-readers.

Services

The Regulations also apply to the following services provided to consumers on or after 28 June 2025:

electronic communications services, other than transmission services used for the provision of machine-to-machine services;
services providing access to audiovisual media services;
websites, mobile device-based services including mobile applications, electronic tickets and electronic ticketing services, delivery of transport service information, including real-time travel information and interactive self-service terminals located within the territory of the EU for air, bus, rail and waterborne passenger transport services;
interactive self-service terminals located within the territory of the EU for urban and suburban transport services and regional transport services;
consumer banking services;
e-books and dedicated software; and
e-commerce services.

Competent Authorities

Each EU Member State will designate competent authorities responsible for enforcing the EAA. In Ireland the following bodies have been designated as competent authorities.

Market Surveillance Authority
Competition and Consumer Protection Commission (CCPC): Responsible for products to which the regulations apply.
Compliance Authorities for Service
- Commission for Communications Regulation: Electronic Communication Services and Emergency Communications.
- Coimisiún na Meán: Services related to audiovisual media services.
- Irish Aviation Authority: Air passenger transport services.
- National Transport Authority: Bus, rail, waterborne transport services.
- Central Bank of Ireland: Consumer banking services.
- CCPC: Services related to E-books and E-commerce.
National Disability Authority
Advises relevant authorities on matters related to the accessibility requirements under the directive and these regulations.

How to prepare

For companies, the EAA presents a challenge but also an opportunity. By proactively addressing these requirements, organisations can not only comply with the EAA but also unlock new opportunities for innovation and customer engagement. The following actions should be undertaken:

Conduct an accessibility audit: Evaluate your current products and services to identify areas that need improvement. This includes websites, mobile apps, and any digital interfaces.
Implement accessibility features: Integrate features such as screen reader compatibility, keyboard navigation, and high-contrast modes to make digital content accessible.
Train your team: Ensure that your development and design teams are well-versed in accessibility standards and best practices.
Engage with users: Involve people with disabilities in the testing and feedback process to ensure that your solutions meet their needs.