AgID Guidelines on Digital Accessibility: What Changes with Determination No. 38 of March 4, 2026

The operational framework for the European Accessibility Act is finally complete. AgID has published the missing technical rules, verification criteria, and control tools. Here's what companies need to know.

The EAA had obligations. Now it also has instructions.

The European Accessibility Act has been in effect in Italy since June 28, 2025. From that date, companies offering digital services to consumers—from e-commerce to banking services, from transportation to electronic communications—are required to ensure 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 in compliance?

On March 4, 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?

Scope of application

The Guidelines are addressed to both Public Administrations and private entities operating in the sectors covered by the EAA:

• E-commerce
• Banking and financial services
• Transportation
• Electronic communications
• Audiovisual media
• E-books and digital publishing

The exemption for the microbusinesses (fewer than 10 employees and an annual turnover of less than 2 million euros), with an important exception: those who have received public or private funding — including PNRR funds — intended 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, which has already been available in Italian since 2023, is due to the fact that the harmonized 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 Cards

Among the most relevant tools introduced by the Guidelines are the Control cards specifications for:

• Websites
• Digital documents
• Mobile apps

These sheets constitute the practical tool that AgID will use for verification and which 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 time stamping. This is a new organizational requirement that 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 just the consumer-facing component.

Enforcement becomes operational

On March 11, 2026, one week after the publication of the Guidelines, AgID activated the whistleblower platform. Users can now report digital services that do not comply with the accessibility requirements set forth 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 the reporting platform, the digital accessibility oversight system in Italy is now fully operational. Audits can start either ex officio or upon user reports.

What to do now

For companies covered by the EAA, the time to act is now. The AgID Guidelines are not an announcement of principle-they are the concrete tool by which compliance will be measured.

Steps to consider:

1. Assess the current state Of its digital services with respect to WCAG 2.1 AA and EN 301 549
2. Prepare the control sheets according to the format given in the Guidelines
3. Implementing a process For digital signature with time stamping of attestations
4. Planning remediation Of identified nonconformities, with priority given to the most critical barriers
5. Document everything: in case of verification, compliance is demonstrated with structured evidence

The normative frame of reference