Note: this article describes the Italian regulatory framework (Legislative Decree 82/2022, AgID). The rules that apply in your country may differ: in the United Kingdom, for example, the main references are the Equality Act 2010 and the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (PSBAR), while the European Accessibility Act is EU legislation that does not apply in the UK and only concerns products and services offered in the European Union.

With the Legislative Decree 82/2022 which transposes in Italy the Directive (EU) 2019/882 (European Accessibility Act), digital accessibility becomes a legal requirement for certain categories of digital consumer products and services.

But beware: not all brochure or institutional sites are automatically subject to the obligations from 28 June 2025.

Who is obliged to comply?

The obligation concerns the digital services indicated by the EAA including:

  • E-commerce Services (when the consumer can conclude an online contract, e.g. purchase or payment).
  • Electronic Communication Services.
  • Services providing access to audiovisual media (streaming platforms, TV apps, etc.).
  • Digital elements of passenger transport services (sites, apps, ticketing, real-time information).
  • Consumer banking services.
  • E-books and dedicated software.

Normative references

What does 'accessible' mean?

A site is considered accessible when it can also be used by persons with sensory, motor or cognitive disabilities. Commonly applied requirements refer to WCAG 2.1 level AA guidelines including:

  • Compatibility with screen readers and assistive technologies.
  • Full keyboard navigation.
  • Adequate colour contrast.
  • Alternative texts for images, subtitles for videos, transcripts for audio.
  • Correct semantic structure of HTML code.

Who is subject to the obligation?

  • Companies and providers of consumer-facing digital services (e.g. e-commerce platforms).
  • SaaS Providers and developers offering digital services to the public.

B2B or purely informative showcase sites are not obliged unless they are part of a service covered by the directive.

Exemptions and waivers

  • Microenterprises (fewer than 10 employees and turnover ≤ EUR 2 million) are exempted from the obligation for services but not for the production of software or sites for third parties.
  • The exemption may be invoked for "disproportionate burden" but the evaluation must be documented and retained for at least five years.

Main deadlines

  • 28 June 2025: compliance obligation for digital services covered by the EAA (new and current).
  • Until 28 June 2030: services may continue to use digital products already in use before 2025, but must still comply with the requirements when updated.

Sanctions and controls

The supervisory body is AgID, which can:

  • Request corrective measures.
  • Apply the administrative penalties provided for by Legislative Decree 82/2022 and Law 4/2004, which are proportionate to the operator's turnover (up to 5%).

For the amounts and the procedure that would apply in your own case, check the text of the decree with your own advisers.

Why does it make sense to act anyway?

  • Preventing legal and reputational risks.
  • Offer an inclusive experience to all users.
  • Improving SEO and usability.
  • Showing concern for social responsibility.

This article is for information only and does not constitute legal advice: check the obligations that apply to you with your own advisers.