The European Accessibility Act[1]
(EAA) was implemented into Irish law through the European Union (Accessibility Requirements of Products and Services) Regulations 2023. The Regulations will apply from 28 June 2025 and will have significant consequences for:
- Economic operators of in-scope products, such as computers and operating systems, ATMs, ticketing and check-in machines and smartphones, and
- Providers of in-scope services, such as e-commerce, consumer banking, e-books, access to audio-visual media services, electronic communications services and air, bus, rail and waterborne passenger transport services
With less than a year to go, our Technology team considers the importance of an accessibility statement for providers of in-scope services and what businesses should be doing now to ensure compliance in advance of the deadline.
For more information on the EAA, please see our previous articles:
- Overview of the European Accessibility Act which outlines the products and services which will be subject to the EAA and gives an overview of the accessibility requirements
- Update on the European Accessibility Act in Ireland here which gives an overview of what businesses should be doing to prepare for the EAA
- European Accessibility Act Implemented into Irish Law which provides an overview of the Irish implementing measures including the penalties for breaches of these measures
Accessibility statements
The EAA requires that providers of in-scope services produce a public facing document which sets out information on how the in-scope service it provides meets the relevant accessibility requirements. This document, commonly referred to as an “accessibility statement”, must be included in either the businesses’ general terms and conditions, or in an equivalent document.
The required information must include the following:
- A general description of the service in accessible formats
- Descriptions and explanations necessary for the understanding of the operation of the service, and
- A description of how the relevant accessibility requirements are met by the service
This information must be made available to the public in written and oral format, including in a manner that is accessible to people with disabilities.
What should in-scope businesses be doing?
Accessibility statements serve as the public declaration of how a business complies with the EAA, so they should be drafted towards the end, or near completion, of the EAA compliance process.
For achieving compliance with the EAA generally, the following steps businesses should be taken, noting the compliance deadline is June 2025:
1. Identify whether any of the services and/or products provided by your business are subject to the EAA |
2. If your business provides any in-scope products, identify the role in the supply chain that your business plays |
3. Identify whether your business can avail of any exemptions under the EAA |
4. Identify the precise obligations that your business is subject to |
5. Identify the accessibility requirements that will apply to your product / service and undertake an impact analysis |
6. Conduct an accessibility audit to identify accessibility gaps in products and services |
7. Collaborate with different teams in your organisation to make adjustments to your products / services where required |
8. For in-scope services, publish an accessibility statement on or before 28 June 2025 |
For more information on the implementation on what in-scope businesses need to do in advance of the EAA coming into force, contact a member of our Technology team.
The content of this article is provided for information purposes only and does not constitute legal or other advice.
[1] (Directive 2019/882)
