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.

Digital accessibility has become an absolute priority for companies and public administrations. With the European Accessibility Act (EAA) applicable since 28 June 2025, accessibility requirements concern certain digital products and services aimed at consumers (for example e-commerce, banking services, transport, electronic communications and e-books), with an exemption for microenterprises providing services (fewer than 10 employees and an annual turnover of no more than EUR 2 million). Whether an organisation falls within the scope has to be checked case by case, depending on the country, the sector and the service offered.

In this context, it is crucial to realise that the implementation of a simple accessibility widget is not enough to make a site accessible and compliant with the applicable requirements. It is necessary to adopt a more structured approach, including a thorough audit of the site and the drafting of an accessibility declaration in accordance with the guidelines of the Agenzia per l'Italia Digitale (AgID).

The limits of accessibility widgets

Accessibility widgets are tools that offer features such as enlarging text, changing contrast and voice reading of content. Although they can improve site usability for some users, they have several limitations:

  • They do not guarantee full compliance: Widgets do not correct structural problems of the site, such as bad semantics of HTML code or lack of textual alternatives for images .
  • They can create conflicts with assistive technologies: Some widgets interfere with screen readers and other tools used by persons with disabilities, impairing the user experience.
  • Not a substitute for accessible design Accessibility must be integrated at an early stage of site design, following the Web Content Accessibility Guidelines (WCAG) 2.1 level AA .

The importance of the accessibility audit

An accessibility audit is an in-depth analysis of the website or mobile application to identify and correct barriers that prevent access to content by people with disabilities. This process includes:

  • Technical Verifications: Analysis of the source code to ensure the correct semantic structure and appropriate use of HTML elements.
  • Manual tests: Evaluating the usability of the site through the use of assistive technologies, such as screen readers and alternative keyboards.
  • Testing with panels of users with disabilities Gathering feedback from people with different disabilities is a further step, available on request: it is not included in the standard audit.

The audit serves to identify the barriers on the agreed pages and features (the basic audit covers up to 20 pages), with reference to WCAG 2.1/2.2 level AA and with both automated and manual checks by human auditors. Technical conformance with WCAG does not, on its own, amount to meeting every legal obligation: those depend on the country, the type of organisation, the sector and the service.

The accessibility declaration: when it is required

The accessibility declaration is the document in which an organisation itself states the accessibility status of its website or mobile application found on the date the declaration is drawn up, the content that is not accessible and the feedback channels. It is a self-declaration, not a certificate issued by a third party: whether it is mandatory, for whom and in what form depends on the country, the type of organisation, the sector and the service. In Italy, publication of the declaration using the AgID template is provided for:

  • Public administrations: They must publish the declaration by 23 September each year .
  • Private parties those referred to in article 3, paragraph 1-bis of Law 4/2004, that is, those with an average turnover of more than EUR 500 million over the last three years of activity. For the services covered by Legislative Decree 82/2022 (which transposes the EAA), the accessibility and information obligations must be checked case by case, with an exemption for microenterprises providing services (fewer than 10 employees and an annual turnover of no more than EUR 2 million).

The declaration must be drawn up following the template provided by AgID and must include:

  • Compliance Status Indicate whether the site is compliant, partially compliant or non-compliant with WCAG 2.1.
  • Non-accessible content: List the sections of the site that are not accessible and the reasons why.
  • Feedback mechanisms: To provide a channel through which users can report accessibility problems.
  • Technical Information: Details of the CMS used, supported operating systems and dates of publication and updating of the site .

Digital accessibility cannot be guaranteed simply by implementing a widget. A holistic approach must be taken that includes a thorough audit of the site and the drafting of an accessibility statement that reflects the actual state of the site. This approach reduces barriers for users and the risk of disputes.

This article is for information only and does not constitute legal advice: check the obligations that apply to you with your own advisers. For information and support on the technical accessibility work on your site, you can request more information.