The operational framework for the European Accessibility Act is finally complete. AgID has published the technical rules, verification criteria, and control tools that were missing. Here's what companies need to know.
The EAA had obligations. Now it also has instructions.
The European Accessibility Act has been in force in Italy since June 28, 2025. From that date, businesses offering digital services to consumers – from e-commerce to banking services, from transport to electronic communications – are required to guarantee the accessibility of their digital products and services.
What was missing until a few weeks ago was the operational piece: how is compliance verified? What criteria does AgID use in inspections? How can a company prove it is compliant?
On 4 March 2026, with the Determination No. 38/2026, the Agency for Digital Italy has published the new Digital Service Accessibility Guidelines, in implementation of art. 21 of Legislative Decree 82/2022. The document is available in the Transparent Administration section of the AgID website.
What do the new Guidelines provide for?
Scope
The Guidelines are aimed at both Public Administrations and private entities operating in sectors covered by the EAA:
- E-commerce
- Banking and financial services
- Transport
- Electronic communications
- Audiovisual media
- E-books and digital publishing
The exemption for Small businesses (fewer than 10 employees and annual turnover less than 2 million euros), with an important exception: those who received public or private funding — including PNRR funds — allocated for improving accessibility cannot make use of this exemption.
Reference standard: WCAG 2.1, not (yet) 2.2
The Guidelines refer to the standard EN 301 549 and all WCAG 2.1 level AA. The decision not to include WCAG 2.2 – already available in Italian since 2023 – depends on the fact that the harmonised European standard has not yet been formally updated by the European Commission. AgID has adhered to the current regulatory reference, but it is reasonable to expect an update as soon as the EU adopts the new version of EN 301 549.
Structured control sheets
Among the most relevant tools introduced by the Guidelines are the Control sheets Specifications for:
- Websites
- Digital documents
- Mobile applications
These sheets constitute the practical tool that AgID will use for checks and that companies can adopt to document and demonstrate their compliance.
Digital signature with timestamp
All attestations and documents related to the accessibility verification must be digitally signed with timestamp. This is a new organisational requirement which companies will have to integrate into their internal processes.
B2B/B2C mixed services: full compliance
A particularly significant clarification concerns services aimed simultaneously at professionals and end consumers. If a digital service — for example, an e-commerce platform — serves both business and private customers, the entire service must comply, not only the consumer-facing component.
Enforcement becomes operational
On 11 March 2026, one week after the publication of the Guidelines, AgID activated the Non-compliance reporting platform. Users can now report digital services that do not comply with the accessibility requirements provided for by Legislative Decree 82/2022 directly to the Agency.
The platform is designed to evolve over time into a direct communication channel between companies and AgID, through which operators will also be able to communicate the corrective measures adopted.
With the Guidelines and reporting platform, Italy's digital accessibility monitoring system is now fully operational. Checks can be initiated either automatically or upon user report.
What to do now
For companies within the scope of the EAA, the time to act is now. The AGID Guidelines are not an announcement of principle: they are the concrete tool with which compliance will be measured.
The steps to consider:
- Assess the current situation of its digital services with respect to WCAG 2.1 AA and EN 301 549
- Prepare the control sheets according to the format indicated in the Guidelines
- Implement a process for the digital signature with time stamping of attestations
- Plan remediation of the non-conformities identified, prioritising the most critical barriers
- Document everythingIn the event of an inspection, compliance is demonstrated with structured evidence.
The regulatory framework
| Norma | Content |
|---|---|
| EU Directive 2019/882 (EDA) | Accessibility requirements for digital products and services |
| Legislative Decree 82/2022 | Italian implementation of the EAA |
| Law 4/2004 (Stanca Law) | Accessibility for public administrations and large companies (>€500M) |
| Determination of AgID no. 38/2026 | Operational Guidelines on Service Accessibility |
| EN 301 549 | Harmonised European technical standard |
| WCAG 2.1 AA | Technical standard for web accessibility |
