Since 28 June 2025, the framework derived from the European Accessibility Act (EU Directive 2019/882), transposed by Italian Legislative Decree 82/2022, has applied in Italy.
One of the most common misunderstandings is that the law automatically requires every company website to meet the same accessibility requirements. That is not the case: the decree applies to specific products and services identified by the legislation.
Which services fall under the European Accessibility Act?
The services covered by Legislative Decree 82/2022 include, among others:
- electronic communications services;
- services providing access to audiovisual media services;
- certain digital services related to passenger transport;
- consumer banking services;
- e-books and dedicated software;
- e-commerce services.
For a company website, the right question is therefore not “does my site exist after 28 June 2025?”, but “does the service I offer fall within the scope of the decree?”.
Does an online shop fall within the scope?
Yes, e-commerce services are explicitly among the services covered. This makes accessibility particularly relevant for online shops and online services that let consumers complete a transaction or buy a product or service.
Are micro-enterprises exempt?
The decree provides an exemption for micro-enterprises that provide services.
For the purposes of the law, a micro-enterprise is a business that employs fewer than 10 people and has an annual turnover or annual balance sheet total not exceeding €2 million.
This means it is not correct to say that the obligation only applies once a company exceeds both 10 employees and €2 million at the same time. What you need to check is whether or not the business meets the definition of a micro-enterprise.
The exemption covers micro-enterprises that provide services. Micro-enterprises dealing with products are treated differently.
So can a micro-enterprise ignore accessibility?
No, at least not as a design choice. Being exempt from the EAA does not mean accessibility is pointless, or that other obligations cannot apply in specific cases.
An accessible site improves usability, code quality, keyboard navigation, readability, compatibility with assistive technologies and often the overall robustness of the interface.
Not every site published after 2025 is automatically covered
The date of 28 June 2025 marks when the decree started to apply to the products and services within its scope. There is no general rule that every new site published after that date must comply with the EAA regardless of the service offered or the size of the business.
There are also transitional provisions for certain services and products already in use before that date.
What does it mean to make a digital service accessible?
The requirements concern the ability of people with disabilities to use the service in a way that is perceivable, understandable, operable and robust. In web work this translates into concrete aspects such as:
- full keyboard navigation;
- sufficient contrast between text and background;
- alternative text for informative images;
- correct labels for forms and controls;
- a visible focus indicator;
- a consistent semantic structure;
- understandable error messages;
- compatibility with screen readers and assistive technologies;
- content and features that can be used without relying solely on colour, motion or complex gestures.
Disproportionate burden and fundamental alteration
The law also includes provisions on disproportionate burden and on fundamental alteration of the nature of the product or service. These are not automatic exemptions, however: where applicable, they require a specific assessment and, in the cases provided for, documentation.
What penalties apply?
Breaches of Legislative Decree 82/2022 are subject to administrative fines. The amount depends on the type of breach, how serious the non-compliance is and the number of users affected.
For services, the competent supervisory authority is mainly AgID (the Agency for Digital Italy), within the limits set by the decree.
How to tell whether your site falls under the EAA
- identify the service the site actually provides;
- check whether it is among those listed in Legislative Decree 82/2022;
- check whether your business meets the definition of a micro-enterprise;
- check any other accessibility obligations that apply to your sector;
- if the service is covered, plan a technical and organisational accessibility audit.
Official sources
- EU Directive 2019/882 – EUR-Lex
- Legislative Decree 82/2022 – Gazzetta Ufficiale (Italian)
- AgID FAQ on the European Accessibility Act (Italian)
Note: this article is a technical, informative summary and does not replace a legal assessment of a specific company’s situation.
If you need to design or improve a site with attention to accessibility, performance and technical quality, see my web accessibility services or contact me.