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 States, for example, the main references are the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act, while the European Accessibility Act applies only to products and services offered in the European Union.

Digital accessibility has become a priority for businesses and public administrations. With the European Accessibility Act (EAA) applicable since June 28, 2025, accessibility requirements also concern the private sector. The EAA covers certain digital products and services offered to consumers (for example e-commerce, banking services, transportation, electronic communications, and e-books), with an exemption for microenterprises that provide services (fewer than 10 employees and annual turnover of no more than 2 million euros). Whether an organization falls within the scope has to be checked case by case, based on the country, the sector, and the service offered.

In this context, it is crucial to understand that the implementation of a simple accessibility widget is not enough to make a site accessible and compliant with the applicable requirements. A more structured approach must be taken, including a thorough audit of the site and the drafting of an accessibility statement that complies with the guidelines of the Agency for Digital Italy (AgID).

The limitations 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 in the site, such as poor semantics of HTML code or lack of text alternatives for images .
  • They can create conflicts with assistive technologies: Some widgets interfere with screen readers and other tools used by people with disabilities, impairing the user experience.
  • They are not a substitute for accessible design: Accessibility should be integrated from the earliest stages of site design, following the Web Content Accessibility Guidelines (WCAG) 2.1 level AA .

The importance of the accessibility audit

An accessibility audit is a thorough 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 source code to ensure correct semantic structure and appropriate use of HTML elements.
  • Manual testing: Assessment of site usability through the use of assistive technologies, such as screen readers and alternative keyboards.
  • Involvement of users with disabilities: Gather feedback from people with different disabilities to better understand their needs and improve the user experience.

The audit serves to identify the barriers on the pages and features agreed upon (the base 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, by itself, amount to meeting every legal obligation: those depend on the country, the type of organization, the sector, and the service.

The accessibility statement: when it is required

The accessibility statement is the document through which an organization communicates the accessibility status found for its website or app as of the drafting date, the content that is not accessible, and the channels for reporting problems. It is not a certification of compliance: whether it is mandatory, for whom, and in what form depends on the country, the type of organization, the sector, and the service. In Italy, publication of the statement following the AgID model is provided for:

  • Public administration: They must publish the statement by September 23 each year .
  • Private entities: those referred to in Article 3, paragraph 1-bis of Law 4/2004, that is, those with an average turnover of more than 500 million euros 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 have to be checked case by case, with an exemption for microenterprises that provide services (fewer than 10 employees and annual turnover of no more than 2 million euros).

The statement must be prepared 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.
  • Inaccessible 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 about the CMS used, supported operating systems, and dates the site was published and updated .

Digital accessibility cannot be ensured simply through the implementation of 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 complaints.

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