European Accessibility Act Compliance in Italy

The decree applies to economic operators, which Article 2(1)(z) defines as manufacturers, authorised representatives, importers, distributors and service providers. Article 1(2) lists the products: consumer general purpose computer hardware and its operating systems, self-service payment terminals and self-service terminals used for covered services, consumer terminal equipment used for electronic communications or for access to audiovisual media services, and e-readers. Article 1(3) lists the services: electronic communications except transmission services used for machine-to-machine services, services giving access to audiovisual media services, the websites, mobile services, electronic tickets, travel information and interactive self-service terminals of air, bus, rail and waterborne passenger transport, consumer banking, e-books and dedicated software, and e-commerce.

Article 2(1)(hh) defines e-commerce services as services that a consumer requests individually and that are provided at a distance by electronic means, through websites and mobile device-based services, with a view to concluding a consumer contract. Section 8.1 of AgID's guidelines adds that a service offered to professional users as well as to consumers has to meet the requirements, and gives the example of an e-commerce service that sells hardware to consumers and to professionals who buy computers for their work. AgID's FAQ N_82/22_03 confirms that a covered service provided in Italy has to comply even when the provider has its registered office outside the EU.

Article 3(3) exempts micro-enterprises that provide services from the service accessibility requirements, and Article 2(1)(bb) defines a micro-enterprise as an enterprise that employs fewer than 10 persons and has an annual turnover or an annual balance sheet total of no more than EUR 2 million. The exemption covers services only. A micro-enterprise that deals in covered products still has to meet the product requirements, although Article 13(4) frees it from documenting its assessment of whether compliance would fundamentally alter the product or impose a disproportionate burden.

Article 1(5) leaves some website and app content outside the decree: pre-recorded time-based media and office file formats published before 28 June 2025, online maps where the essential information for navigation is given in accessible digital form, third-party content that is outside the operator's control and neither funded nor developed by it, and archives that are not updated or edited after 28 June 2025. Public administrations and the other entities covered by Article 3(1) of Law No. 4 of 9 January 2004 remain subject to that law, as AgID's FAQ N_82/22_10 confirms.

Decreto legislativo 27 maggio 2022, n. 82, Attuazione della direttiva (UE) 2019/882 del Parlamento europeo e del Consiglio, del 17 aprile 2019, sui requisiti di accessibilità dei prodotti e dei servizi (Legislative Decree No. 82 of 27 May 2022 implementing Directive (EU) 2019/882 on the accessibility requirements for products and services). It was adopted under Article 1 and Annex A, No. 17, of Law No. 53 of 22 April 2021, the European Delegation Law 2019-2020. It was published in the Gazzetta Ufficiale, Serie Generale No. 152 of 1 July 2022, and entered into force on 16 July 2022. Under Article 25(1) its provisions have applied since 28 June 2025.

On 19 April 2023 the European Commission sent Italy a letter of formal notice, INFR(2023)2015, for not fully transposing the Directive by the deadline of 28 June 2022. Italy answered with Article 3-bis of Decree-Law No. 69 of 13 June 2023, inserted by conversion Law No. 103 of 10 August 2023, which amended the decree to add a definition of the withdrawal of a product and rules on the information the Italian authorities send to the Commission. The Commission closed the case on 11 December 2025. Decree-Law No. 25 of 14 March 2025, as converted by Law No. 69 of 9 May 2025, and Law No. 199 of 30 December 2025 later amended Article 26 of the decree, on hiring supervision staff, and Law No. 199 repealed its paragraph 2 on hiring at the ministry.

The decree also changes how Law No. 4 of 9 January 2004 applies to service providers. From 28 June 2025, Article 25(3) disapplies several provisions of that law, among them the accessibility statement in its Article 3-quater, for entities that provide services covered by the decree, and AgID's FAQ N_82/22_11 confirms that companies covered by Article 3(1-bis) of that law no longer have to submit that statement when they provide such services.

The decree names no technical standard. Article 3(2) requires services to meet the accessibility requirements in Sections III and IV of Annex I, and Article 14 presumes conformity for products and services that follow harmonised standards whose references are published in the Official Journal of the European Union, or technical specifications, to the extent those cover the requirements.

Section 7.1 of the Linee guida sull'accessibilità dei servizi, adopted by AgID on 4 March 2026, names EN 301 549 as the harmonised standard in force for the general accessibility requirements of services, and section 9 lets a provider send AgID the EN 301 549 and WCAG 2.1 checklists as evidence of conformity. Section 2.2 of the guidelines lists the Italian edition of the standard as UNI CEI EN 301549:2021.

In September 2026 the European Commission's list of harmonised standards had an accessibility entry only for Directive (EU) 2016/2102 on public sector websites and apps, and none for Directive (EU) 2019/882, so the Article 14 presumption is not available under the decree yet. EN 301 549 V3.2.1 applies the WCAG 2.1 level AA success criteria to web content. EN 301 549 V4.1.1, which adopts WCAG 2.2 AA, was published on 2 September 2026 and is not yet cited in the Official Journal.

The Agenzia per l'Italia Digitale (AgID) is the Autorità di vigilanza sui servizi under Article 21(1). It supervises electronic communications, access to audiovisual media services, consumer banking, e-books, e-commerce, and the websites, apps, electronic ticketing and travel information of passenger transport. Self-service terminals used for passenger transport fall to the public bodies that awarded or authorised the transport service (Article 21(6)). For products, Article 17(2) names the Ministero dello sviluppo economico, which Decree-Law No. 173 of 11 November 2022 renamed the Ministero delle imprese e del made in Italy (MIMIT). AgID's FAQ N_82/22_04 adds that audiovisual media services themselves stay with the Autorità per le garanzie nelle comunicazioni (AGCOM) and MIMIT.

Under Article 21(3) AgID examines user complaints. Under Article 3(4) of its regulation on establishing violations and imposing sanctions, adopted by Determination No. 84/2026 of 15 May 2026, complaints go through a dedicated platform, and each complaint may concern only one service provider. AgID runs that platform at segnalazioni.agid.gov.it. The Difensore civico per il digitale starts the pre-investigation under Article 3(1) of that regulation.

If AgID finds a service non-compliant, Article 21(1) requires it to ask the provider to take corrective measures within a deadline that AgID sets. If the provider misses that deadline, AgID sets a period for taking the service offline and, where necessary, withdrawing the app from the store, or adopts measures that block use of the service. For transport services it first obtains the opinion of the Autorità per la regolazione dei trasporti.

Article 24(1) sets an administrative fine of EUR 5,000 to EUR 40,000 for breaching the accessibility requirements or the obligations of manufacturers, importers, distributors and service providers it lists, and the amount depends on the extent of the non-compliance and on how many units and users it affects. Article 24(2) and (3) set a fine of EUR 2,500 to EUR 30,000 for ignoring the authority's corrective orders or for failing to cooperate with it. Article 24(1) adds that the sanction in Article 9(1-bis) of Law No. 4 of 9 January 2004 applies in any case to the companies covered by Article 3(1-bis) of that law, meaning those that offer services to the public through websites or apps with average turnover above EUR 500 million over their last three years of activity. That sanction is a fine of up to 5% of turnover if the company does not comply with a formal warning from AgID.

Under Article 8(5) of the regulation, the Director General of AgID sets each Article 24 fine within the statutory range, based on the seriousness of the breach and the harm caused to users and taking account of the provider's cooperation and overall conduct. Under Article 9(1), sanction and closure decisions are published in extract form on the AgID website.