With the Legislative Decree 82/2022, which implements in Italy the Directive (EU) 2019/882 (European Accessibility Act), digital accessibility becomes a legal requirement for certain categories of Consumer-facing digital products and services.
But beware: not all showcase or institutional sites are automatically subject to to obligations by the June 28, 2025.
Who is obliged to comply?
The obligation covers the digital services specified by the EAA, including:
- E-commerce services (when the consumer can conclude an online contract, e.g., purchase or payment).
- Electronic communication services.
- Services that provide access to audiovisual media (streaming platforms, TV apps, etc.).
- Digital elements of passenger transport services (sites, apps, ticketing, real-time information).
- Consumer-facing banking services.
- E-books and dedicated software.
Normative references
- Directive (EU) 2019/882 - Official text: EUR-Lex
- Legislative Decree No. 82 of May 27, 2022. - Official Gazette
What does "accessible" mean?
A site is considered accessible when it can also be used by people with sensory, motor, or cognitive disabilities. Commonly applied requirements refer to the WCAG 2.1 level AA guidelines, including:
- Compatibility with screen readers and assistive technologies.
- Full keyboard navigation.
- Adequate color contrast.
- Alternative texts for pictures, subtitles for video, transcripts for audio.
- Proper 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 informational showcase sites are not obligated unless they are part of a service covered by the directive.
Exemptions and waivers
- Microenterprises (less than 10 employees and turnover ≤ 2 million euros) Are exempted from the obligation for services, but not for the production of software or sites intended for third parties.
- The waiver can be invoked for "disproportionate burden", but it is necessary to document the assessment and keep it for at least five years.
Key deadlines
- June 28, 2025: compliance obligation for digital services covered by the EAA (new and current).
- Until June 28, 2030: services can continue to use digital products that were already in use before 2025, but must still meet the requirements when updated.
Penalties and controls
The controlling body is AgID, which can:
- Request corrective changes.
- Disable noncompliant services.
- Apply penalties between 5,000 and 40,000 euros.
Why is it worth taking action anyway?
- Preventing legal and reputational risks.
- Provide an inclusive experience for all users.
- Improving SEO and usability.
- Demonstrate attention to social responsibility.
