The verdict in three sentences
Since 28 June 2025, the European Accessibility Act, transposed in Ireland by S.I. No. 636 of 2023, requires accessibility for digital services sold to consumers by businesses with 10 or more employees or more than 2 million EUR in turnover. Compliance means a WCAG 2.2 audit (3,000 to 8,000 EUR), remediation (5,000 to 25,000 EUR) and a published accessibility statement. Irish law provides for fines and even prosecution for non-compliant services, on top of the reputational risk with customers and public buyers.
Who is in scope and what is required
A general counsel first needs to qualify the scope. The EAA targets consumer services: e-commerce, banking, transport, electronic communications, e-books. A purely B2B site may fall outside, but the line is thin as soon as a form, customer portal or booking tool faces the public.
| Situation (2026) | Main obligation | Standard | Enforcement in Ireland |
|---|---|---|---|
| Service microenterprise (under 10 staff and under 2 M EUR) | Exempt for services | WCAG best practice | None |
| B2C e-commerce, 10+ employees | EAA compliance, accessibility information | EN 301 549 / WCAG 2.1 AA, 2.2 recommended | Compliance notices, fines up to 60,000 EUR on indictment |
| Consumer banking and insurance online | EAA compliance | EN 301 549 / WCAG | Same, sector regulators involved |
| Large enterprise with customer portals | EAA + contractual requirements | WCAG 2.2 AA | Same + procurement exclusion risk |
| Public sector body | Web Accessibility Directive, statement | WCAG 2.1 AA | NDA monitoring |
| B2B site with no public service | Out of strict scope, contractual risk | WCAG recommended | Tender requirements |
WCAG 2.2 adds 9 success criteria over 2.1, including focus visibility, target size and accessible authentication. Auditing against 2.2 now avoids a second audit when the harmonised standard catches up.
What compliance costs
Cost depends mostly on the number of page templates, not pages. A 200-page site built on 12 templates is cheaper to fix than a 40-page site built page by page.
| Item (2026 estimate, excl. VAT) | Corporate site 10-15 templates | E-commerce 20-30 templates | Complex customer portal |
|---|---|---|---|
| WCAG 2.2 sample audit | 3,000 to 4,000 EUR | 4,500 to 6,500 EUR | 6,000 to 8,000 EUR |
| Technical and design fixes | 5,000 to 10,000 EUR | 10,000 to 18,000 EUR | 15,000 to 25,000 EUR |
| Verification re-audit | 1,000 to 1,800 EUR | 1,500 to 2,500 EUR | 2,000 to 3,000 EUR |
| Accessibility statement | 400 to 700 EUR | 600 to 1,000 EUR | 800 to 1,400 EUR |
| Editor training (1 day) | 1,000 to 1,600 EUR | 1,000 to 1,600 EUR | 1,600 to 2,800 EUR |
| Total timeline | 6 to 8 weeks | 8 to 10 weeks | 10 to 12 weeks |
If the site is more than 5 years old, compare with an accessible rebuild: building accessibility in from the start usually adds 10 to 20 % to a new project, against 30 to 60 % when retrofitting.
Planning without paralysing the business
The effective method has four steps: audit a representative sample of 15 to 20 pages, prioritise blocking issues (forms, checkout, login), fix by template, then re-audit and publish the statement with the conformance level. An honest statement with a dated action plan beats having none.
Mini case study
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Aoife, general counsel of a 140-employee furniture retailer selling online from Dublin, gets a warning from her insurer. The site has 24 templates. Chosen quote: audit 5,500 EUR, fixes 14,000 EUR, re-audit 2,000 EUR, statement 800 EUR, training 1,400 EUR, for 23,700 EUR over 9 weeks. Beyond enforcement risk, form and contrast fixes reduce checkout abandonment. With 2.4 M EUR of online sales, a 1 % conversion gain is worth 24,000 EUR a year, so payback comes in under 12 months.
FAQ
Is a pure B2B site subject to the EAA?
In principle no, since the EAA targets consumer services. But many large accounts and public buyers now require WCAG 2.1 AA conformance of at least 75 % in tenders.
Are 50 EUR-a-month accessibility overlays enough?
No. These widgets do not fix the code and do not make a site WCAG conformant; several US lawsuits targeted sites that used them.
How long does a WCAG audit take?
Allow 5 to 12 working days depending on sample size, then one week for the report and prioritisation.
Should the audit be repeated every year?
A yearly re-audit at 1,000 to 3,000 EUR is recommended, since every new page or feature can introduce failures.
What must the accessibility statement contain?
The conformance status, inaccessible content, exemptions claimed, a feedback contact and the enforcement procedure. It should be reachable from every page, usually through the footer.
Let's scope your project. Send us your site URL and number of templates: we will price the WCAG 2.2 audit, the remediation and a 6 to 12 week schedule. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
