European Accessibility Act

Digital accessibility is no longer merely good practice: it is now a legal obligation with enforceable penalties. On 11 March 2026, AgID — Italy's Agency for Digital Italy — published its guidelines on the accessibility of services, mandated by Legislative Decree 82/2022, which transposes the European Directive 2019/882, known as the European Accessibility Act (EAA). For thousands of Italian companies, the question is no longer "whether" to comply, but "how" and with what urgency.

The measure closes a regulatory cycle launched in Brussels in 2019 and arrives after a public consultation, the opinion of the Unified Conference, the Data Protection Authority and formal notification to the European Commission. This is not a statement of principle: it is a technical guide with concrete requirements, aimed at those who design, develop and manage digital services on the Italian and European market.

Who is affected and why you cannot ignore it

Unlike the accessibility rules for the public sector — already in force for years for public administrations and large bodies — the EAA directly targets private entities in specific sectors. The provisions concern all providers of electronic communication services, those offering access to audiovisual media, passenger transport services, e-commerce platforms, retail banking services, e-books and the software dedicated to reading them.

If you run an e-commerce site, a home banking app, a streaming platform, a travel booking service, or distribute digital content in any form, you fall squarely within the scope. And the list of affected parties is set to widen as sector authorities refine their interpretation: AgID has already forwarded the text to the Transport Regulation Authority and to AGCOM for their respective areas of competence.

The reporting platform: the real risk for those who fail to comply

One of the most underestimated aspects of the measure is its concrete enforcement dimension. AgID has activated a dedicated platform that allows anyone — a customer, a consumer association, a competitor — to report non-compliance with the requirements of Legislative Decree 82/2022. The platform is already online and accessible, and is designed to become, over time, a direct channel between operators and the Agency for managing compliance obligations.

This radically changes the perspective compared with previous regulations, which often remained on paper. The risk is not abstract: an inaccessible service can be reported today, by any user, through a formalised process. Waiting is not a defensible strategy.

What the guidelines require, technically

The AgID document aligns with the international standards WCAG 2.1 and 2.2 — the W3C's Web Content Accessibility Guidelines — but places them within a binding regulatory framework. The requirements are organised around four fundamental principles that concern both design and code.

Perceivability

Content must be usable through alternative channels. Images without alternative text, videos without subtitles, unstructured PDF documents: anything that assumes a single sensory mode of access is non-compliant. For an e-commerce site this means alt text on every product image, transcripts for videos, and downloadable documents in an accessible format.

Operability

Interfaces must be fully navigable by keyboard and compatible with assistive technologies such as screen readers and braille displays. No action should require physical interactions that not all users are able to perform. Dropdowns that open only on mouse-over, forms that time out without warning, and visual CAPTCHAs with no audio alternative are all elements to be eliminated.

Understandability and robustness

Clear text, predictable behaviour, explicit support for input errors. And code written to be interpreted correctly by assistive tools, which entails semantically correct HTML, appropriate use of ARIA landmarks, and a hierarchical heading structure. These are not details: they are the foundation on which all accessibility technologies rest.

Accessibility and SEO: the advantage many have yet to grasp

It would be a mistake to reduce the EAA to a bureaucratic obligation. European data indicate that around 87 million people with disabilities live in the European Union. An inaccessible website or service systematically excludes a huge share of potential customers — and it does so silently, without the company even realising it.

There is, however, a second advantage that is often overlooked: accessibility and technical SEO overlap almost completely. Google favours sites with a correct semantic structure, a heading hierarchy, alt text on images and mobile navigability. All of these requirements coincide point by point with the WCAG standards. Investing in accessibility is not a pure cost: it is an investment with a double return, on compliance and on organic visibility.

AgID's technical working groups: what to expect in the coming months

AgID has set up joint technical working groups with operators in the affected sectors — publishing, transport, audiovisual media and banking services — with the aim of gathering practical concerns, promoting a consistent interpretation of the provisions and defining operational FAQs to be published on the institutional website.

The direction is clear: the working groups do not slow down the obligations, they clarify them. Those waiting for the FAQs before starting to work on compliance are already behind competitors who are moving now.

How A126 approaches these compliance journeys

Complying with the EAA is not a one-off intervention on the code. It requires an analysis of existing digital processes, a technical review of the interface, work on UX, content and infrastructure, and ongoing monitoring over time. Companies that tackle this transition in a fragmented way risk duplicating work or leaving critical areas uncovered.

At A126 Corporate Advisors we work as strategic partners: we start with an audit of non-compliance against the WCAG 2.1/2.2 AA standards and the EAA requirements, produce a report with a prioritised remediation plan, and then support the technical team through implementation — whether that means proprietary web development, the revision of an existing e-commerce site, or the adaptation of a custom management system.

Accessibility must be built into the code, not layered on top. A site built with a correct semantic architecture from the outset is lighter, faster, easier to maintain and more visible on search engines. Retrofitting legacy architectures is possible, but it costs twice as much and delivers half the results.

If you want to understand where you are exposed today, book a free 15-minute exploratory consultation at a126.it/contatti. We will analyse your situation and tell you what to do, with no obligation.