Website accessibility in Italy: who must comply and what AgID checks

Since June 28, 2025, digital services sold to consumers in the EU have to be accessible to people with disabilities. The obligation comes from the European Accessibility Act, Directive (EU) 2019/882, which Italy transposed with Legislative Decree 82/2022. For almost a year there was no clear procedure to enforce it in Italy. Then, on May 15, 2026, AgID (the Agency for Digital Italy) adopted its supervision regulation with determination no. 84. A single user complaint can now end with the service being taken offline.

Who must comply

Article 1 of the decree lists the sectors: e-commerce, consumer banking, electronic communications, access to audiovisual media services, e-books and passenger transport. For most companies the relevant one is the first, meaning a website or app where a consumer concludes a contract at a distance: an online store, a booking. A brochure website with no purchases or bookings is normally out of scope.

Microenterprises providing services are exempt, meaning fewer than 10 people and an annual turnover or balance sheet total of up to 2 million euros (Article 3 of the decree). Services sold only to professionals and businesses are out too, but the AgID guidelines on services point out that a store open to both consumers and businesses has to be accessible in full.

Very large companies have an older obligation as well. Law 4/2004 applies to public administrations and to private companies with an average turnover above 500 million euros over the last three years, for the websites and apps through which they offer services to the public, in any sector and even without online sales.

What the website must do

Annex I of the directive asks for websites and apps that are perceivable, operable, understandable and robust. You can't measure any of that as written: the technical reference is the EN 301 549 standard, which for web content adopts WCAG 2.1 level AA. In practice that means enough contrast, everything usable from the keyboard, alternative text, labeled form fields, pages that survive zooming.

Two documents are also required. The accessibility information goes in the general terms and conditions or an equivalent document and explains, in an accessible format, how the service meets the requirements (Annex IV of the decree); it's worth adding an address where people can report problems. The disproportionate burden assessment is only needed if a requirement costs too much, and it has to be written down, kept for five years and notified to AgID. Lack of priority, time or knowledge doesn't count as a reason, as recital 66 of the directive says.

The transitional period to June 28, 2030, covers less than people tend to think. It applies to products already in use to provide the service and to contracts signed before June 28, 2025 (Article 32 of the directive). A new service has to be accessible from day one.

How an AgID check starts

Almost always with a user. Under the regulation, anyone can file a complaint about a European Accessibility Act service on AgID's platform. Then:

1. The Digital Ombudsman assesses the complaint and, if it is well founded, writes to the company with what needs fixing and asks how long it will take.
2. AgID's Supervision Area follows the work and can request documents, call hearings or carry out inspections.
3. If the company doesn't comply within a reasonable time, AgID can require the service to be taken offline or the app to be withdrawn from the store.
4. The penalty procedure starts: 30 days to respond or ask for a hearing, a formal warning with a binding deadline, 90 days to close (Articles 6 and 7 of the regulation).

For an online store, step 3 hurts more than the fine: while the service is offline, it sells nothing.

The fines are set by Article 24 of Decree 82/2022:

• €5,000 - the minimum for a service that does not meet the requirements
• €40,000 - the maximum for the same breach

Ignoring AgID's requests or refusing to cooperate with the checks carries a separate fine of 2,500 to 30,000 euros (same Article 24). Companies under Law 4/2004 that ignore the formal warning face a fine of up to 5% of turnover. Decisions are published in summary on AgID's website (Article 9 of the regulation).

What axe-core found on a site we look after

The site belongs to a microenterprise, which the decree doesn't cover. On October 10, 2026, we still ran nine of its pages through axe-core, an open-source tool that checks the WCAG 2.1 A and AA criteria that can be tested automatically, at 1440 and 390 pixels wide. On desktop, five of the nine pages had at least one error; on mobile, all nine did.

There were four distinct problems. On mobile the WhatsApp button showed only its icon, so to a screen reader it was a button with no name, on every page. The label on the review stars sat on an element that can't carry one, so it was never read out. The map on the contact page was marked up as an image but contained the zoom buttons. And on a product page the numbers of the inactive steps used the light gray of the borders: a contrast of 1.28 to 1, where WCAG 2.1 asks for at least 3 to 1 on large text.

Each fix took a few lines: an aria-label on the WhatsApp link, role="img" on the stars, role="region" on the map, a darker gray for the numbers. When we ran it again locally on the fixed version, axe-core found no problems on desktop or on mobile.

The scan also flagged other low-contrast text, but it was text caught halfway through a fade-in animation, and with reduced motion it went away. If you run it on your own site and the site honors reduced motion, turn it on first, or you'll spend time chasing errors that aren't there.

Some things axe-core can't see at all. It can't tell whether alternative text actually describes the image, or whether a purchase can be completed with the keyboard alone. We haven't done that manual test, with keyboard and screen reader, on that site yet. That's why we don't read a clean result as WCAG conformance, and we don't claim it.

Where to start if you sell online

The first step is an automated scan like ours, on desktop and mobile and with reduced motion, which clears out the certain errors.

The second is by hand, on the path that brings in money: find a product, add it to the cart, enter your details and pay using only the keyboard, then with a screen reader, then at 200% zoom. The parts you didn't write count too, such as the payment form, the chat, the booking calendar and the cookie banner. If one of them isn't accessible, the service isn't either.

If you want to know where your site stands, write to us. We start from the pages of the purchase path and tell you what to fix, in the design and in the code.