New digital accessibility obligations

The requirement for compliance with accessibility obligations for digital services made available to consumers will be binding from 28 June 2025. Relevant regulatory sources include: Legislative Decree 82/2022, which transposed Directive (EU) 2019/882, known as the “European Accessibility Act” (EAA); Law 4/2004, as amended and supplemented, known as the “Stanca Act” (which first introduced accessibility obligations for public authorities); Law 120/2020, which extended the subjective scope of the Stanca Act to the private sector as well, with a focus on businesses that provide essential services of general interest through digital channels.

Who is obliged to comply with the regulations?

Digital accessibility obligations apply specifically to: 

- Private economic operators providing digital services to the public, including but not limited to:

• banks, insurance companies, transportation companies and telecommunications operators;
• e-commerce platforms, providers of audiovisual content, marketplaces and online services;
• operators of ATMs, self-service terminals, electronic ticketing and postal services.

- Entities involved in the design, production and marketing of digital tools intended for the general public, including but not limited to:

• web sites and mobile applications;
• electronic devices with user interfaces;
• management or application software accessible by end users. 

Who supervises and what do those who fail to comply risk?

The Agency for Digital Italy (AgID) is responsible for supervising the implementation of the regulations: it can carry out audits, inspections and, in case of non-compliance, take sanctioning and inhibitory measures.

Specifically, in case of violation, AgID can:

- issue a warning setting a deadline for compliance; 

- apply fines:

• up to 5% of the average annual turnover for serious violations committed by entities offering services to the public through websites or mobile applications, with an average turnover, in the last three years of activity, exceeding €500 million;
• between €5,000 and €40,000 for the other subjects, taking into account the seriousness of the violation, the number of users involved and the scope of the inaccessible services;
• additional sanctions of €2,500 to €30,000 in case of non-compliance with AgID warnings or obstruction of inspection activities. 

AgID can also take particularly strong administrative inhibitory measures, including: 

- website blackout or removal of applications from digital stores; 

- temporary or permanent ban on access to non-compliant digital services.