What are the new EU accessibility requirements

Explore the upcoming EU accessibility rules set for June 2025 and their impact on products and services across the region.

In brief

• New EU accessibility requirements will take effect on 28 June 2025, affecting various products and services across the EU.
• Organisations must assess compliance steps to avoid penalties for non-compliance.
• The European Accessibility Act aims to harmonise standards, benefiting consumers and fostering market innovation.

New EU-wide Accessibility Requirements for Products and Services

New EU-wide accessibility requirements will apply to certain types of products and services provided within the EU from 28 June 2025.

Public and private organisations (including those supplying into the EU) should assess the impact of these new requirements on their products and services, identify necessary compliance steps and understand the consequences of non-compliance.

What is the European Accessibility Act?

The European Accessibility Act (Directive (EU) 2019/882) (‘EEA’) is a landmark EU law aimed at facilitating persons with disabilities access to various products and services through common accessibility requirements. It complements EU sectoral legislation on accessibility and must be read together with EU rules on standardisation and market surveillance.

Has Ireland implemented the EEA?

The European Union (Accessibility Requirements of Products and Services) Regulations 2023 (‘Irish Regulations’) transposed the EEA into Irish law and comes into operation on 28 June 2025.

Why is the EEA needed?

Until now, the accessibility requirements for certain products and services have varied across EU countries. The new harmonised rules will drive innovation and competition, as businesses invest in cross-border opportunities previously uneconomic due to the fragmented regulatory regime. This in turn is expected to benefit consumers, through wider and more socially inclusive offerings at more competitive prices.

Application

In-scope consumer products and services include:

• e-commerce websites and mobile applications
• air, road, rail and water passenger transport services (e.g. websites, mobile apps, e-ticketing and transport service information)
• self-service terminals (e.g. interactive information, check-in terminals, ticketing machines and ATMs)
• banking services
• computers and operating systems
• telephony services and related terminal equipment
• digital television services and equipment
• audio-visual services and related equipment
• eBooks and dedicates software

What is required?

Relevant products must comply with the requirements contained in Sections I and II of Annex I (save that self-service terminals must only comply with Section I) and the conformity assessment procedure set out in Annex IV of the EEA.

Manufacturers, importers and distributors of relevant products each have specific obligations, based on their position in the supply chain, which apply before and after products are placed on the EU market. Importers and distributors must be aware of actions which could cause them to assume responsibility for obligations that would otherwise rest with the manufacturer.

All in-scope services must comply with Section III of Annex I, while some services must also comply with Section IV, and satisfy the information requirements contained in Annex V of the EEA.

If a relevant product or service no longer conforms with applicable requirements, immediate corrective measures must be taken, notifications will need to be made to relevant Irish and EU authorities and, in the case of a non-conforming product – this may need to be withdrawn from the market.

What exemptions apply?

Microenterprises that provide in-scope services are exempt.

Other providers of in-scope services and products may be exempt if it can establish, based on a documented assessment, that compliance would fundamentally alter the basic nature of the relevant product or service; or would, based on criteria in Annex VI, impose a disproportionate burden on it. Reliance on these exemptions are generally notifiable to the relevant authority.

Microenterprises that provide in-scope products are not required to document their assessment or notify the market surveillance authority of its reliance on these exemption, but may need to provide the facts behind their assessment if requested, and failing to do so is an offence.

Transitional measures mean that service providers can continue to provide their services using in-scope products until 28 June 2030, and service contracts agreed before 28 June 2025 can continue without modification until they expire, provided this occurs no later than 28 June 2030.

Self-service terminals, such as ATMs and payment terminals, in use before 28 June 2025 can continue to be used for similar services until the end of their economically useful life, but for no more than 20 years from their entry into use.

Harmonised standards and technical specifications

The EEA provides for a presumption of conformity for products and services that meet harmonised standards that are published in the Official Journal of the European Union or technical specifications (as defined under the EU Standardisation Regulation) that deal with the corresponding requirements.

Oversight, enforcement and consumer rights

The Irish Regulations designate the CCPC as the market surveillance authority for in-scope products, and designates the following compliance authorities for in-scope services:

These authorities have extensive supervisory and enforcement powers, including the power to enter and search premises, and to apply to the Irish Circuit Court for an order directing compliance (which may find its way before the High Court). Procedural rules set out in the Irish Regulations include a right of appeal before the District Court.

Consumers (including those located outside of Ireland) can take an action against businesses before the Irish Circuit Court. Public and private entities interested in ensuring that the EEA is adhered to can engage on behalf of or in support of a consumer who makes such an application before the courts.

Companies and their directors, managers, secretaries, and other officers can be found guilty of an offence, and penalties of up to €60,000 fine and/or 18 months’ imprisonment may apply.

Actions to take before 28 June 2025

EU and non-EU organisations should assess whether the products and/or services they provide or intend to provide in the EU are within scope, the availability of exemptions, their accessibility obligations and the impact of the new rules on current design and information for their products and services.

How can EY help?

EY Law Ireland, with EY consulting colleagues, provide clients unique solutions covering legal, technical, people/training, risk and supply chain across the design, implementation and operation of their accessibility compliance framework.

Please contact Rob Haniver in EY Law Ireland or your usual EY contact if you would like to learn more.