As of June 28, 2025, digital accessibility requirements also apply to private companies, and in 2026, the regulations entered the phase where they are actually enforced: the guidelines are final, the reporting platform is active, and inspections have begun.
Many business owners are now discovering that they are subject to this requirement, and their first reaction boils down to a single question: how much work will it entail?
The answer depends on the current state of the website. Some companies are already halfway there without even realizing it; others have a longer road ahead of them. In either case, the starting point is the same, and it’s outlined below.
A website is accessible when anyone—including people with visual, hearing, mobility, or cognitive disabilities—can perceive its content, understand it, navigate through its sections, and interact with its features.
The technical standard is the WCAG, the W3C’s international guidelines, which are organized into three levels of compliance: A, AA, and AAA. European regulations require Level AA.
In practice, this means that an image includes a text description that can be read by a screen reader, that the contrast between text and background remains sufficient even for people with low vision, that every function accessible via the mouse is also accessible via the keyboard, and that a video offers captions.
These requirements apply to a broader audience than the term “disability” might suggest. An accessible website also benefits older adults, people browsing on an older smartphone, those with a slow internet connection, and those viewing the site in a noisy environment, where captions become the only way to follow a video.
Digital accessibility in Italy is based on two coexisting standards.
The 2004 Stanca Act established requirements for the public sector and subsequently extended them to large private companies.
Legislative Decree No. 82 of May 27, 2022, which transposes the European directive, has expanded the scope to cover a large part of the private market: its provisions take effect on June 28, 2025.
This requirement applies to any entity that offers digital products or services to consumers and exceeds at least one of these two thresholds: ten employees or two million euros in annual revenue. The criteria are alternative, so meeting just one is sufficient.
The decree lists the sectors covered: e-commerce, banking services, passenger transportation, electronic communications, e-books, and self-service terminals.
Micro-enterprises that provide services—that is, those with fewer than ten employees and an annual revenue of no more than two million—are exempt from this requirement.
These two conditions must be met together: meeting just one of them brings the company within the scope of the regulation.
Companies that develop websites, portals, or applications on behalf of public agencies follow their own process, with specific requirements and deadlines. This topic is covered in more detail on the page dedicated to the accessibility of public administration websites →
Until 2025, digital accessibility remained largely a regulation on paper. In 2026, the framework was finalized on three fronts: the technical guidelines for compliance, the channel through which consumers can report issues, and the procedure for verification.
The guidelines of the Agency for Digital Italy were adopted on March 4, 2026, by Resolution No. 38/2026, and published in the Official Gazette on March 24.
They provide the technical and operational guidelines for complying with the decree and serve as the basis for the Agency’s compliance audits.
Mandatory compliance remains set at Levels A and AA of WCAG 2.1. As of March 11, 2026, the platform through which consumers can report a digital service that presents barriers is operational: the process is online, free, and open to anyone.
On May 15, 2026, by Resolution No. 84/2026, the Agency adopted the regulation governing the investigation of violations and the exercise of its authority to impose sanctions.
The press release was published in the Official Gazette on May 23.
The regulation does not introduce any new technical requirements: it consolidates procedures that were previously separate into a single document and establishes how an inspection is conducted.
First comes a collaborative preliminary investigation phase, followed by any necessary document reviews and on-site inspections, during which the company has the opportunity to submit comments.
This economic measure marks the end of this process.
For a company, there is only one practical consequence: those with well-organized documentation and a compliance plan already underway enter the collaborative phase with something to show for it.
The guidelines address the issue of disproportionate burden—the provision that allows for the postponement of an intervention when the costs are objectively excessive relative to the size of the business.
Anyone who uses it must document the assessment, retain it for at least five years, and update it at least once a year, as well as whenever the service changes.
A new chapter addresses the privacy of people with disabilities.
The guidelines call for checking cookies, fingerprinting techniques, and accessibility widgets, because some of these tools detect which assistive technology a visitor is using—information that can be used to infer a health condition.
The mandatory information provided to consumers must explicitly state that the service is free of tracking techniques of this kind.
The decree provides for administrative penalties ranging from 5,000 to 40,000 euros for violations of the requirements; for very large companies with an average annual revenue exceeding 500 million, the Stanca Law imposes penalties of up to 5 percent of revenue.
The May 2026 regulation establishes a procedure for handling these figures: a report triggers a review, and the company has the opportunity to intervene and present its case before any financial penalty is imposed.
The details of the European directive that set all this in motion are outlined on the page dedicated to the
European Accessibility Act →.
The consumer submits the complaint through the AgID platform, which will be available starting March 11, 2026.
The Agency evaluates the report and, if it deems it valid, initiates a collaborative process with the company.
The May 2026 regulation provides for document reviews, a hearing, and the opportunity to submit comments before any penalties are imposed.
The current regulatory framework is WCAG 2.1 Levels A and AA, as referenced in the harmonized European standard.
The update that will make WCAG 2.2 a mandatory standard is currently being adopted: it adds six criteria to the same two levels, including the minimum size of elements to be tapped or clicked, keyboard focus that remains visible at all times, and authentication that can be used without requiring memorization.
Anyone designing a website today would be wise to take these into account from the start, because making adjustments later costs more than getting it right from the beginning.
In terms of documentation, the regulations provide for two different tools. Knowing which one applies to your company helps you avoid preparing the wrong document.
Businesses subject to Legislative Decree 82/2022 must provide the accessibility information required by Article 12: they must describe the service, indicate how the requirements are met, and make this information available to consumers along with the general terms and conditions.
Starting in 2026, they will also include a statement certifying that the service does not use tracking techniques from which a disability could be inferred.
This is a different requirement from the declaration required by the Stanca Law, both in structure and content: anyone who prepared the document using the previous form should update it.
The accessibility statement is the public document that reports on the accessibility status of a website or app.
It indicates the level of compliance achieved, lists the content that still needs to be updated along with the reasons why, and provides a feedback channel for users.
It is prepared using the template provided by the Agency for Digital Italy, is updated annually, and applies to public administration entities and private entities with an average annual revenue exceeding 500 million euros over the past three years of operation.
The document describes the actual status of the service. Claiming a higher level of compliance than is actually the case exposes the organization to a twofold risk: a formal risk and a reputational risk.
It is therefore best for it to come after the review and to describe precisely what still needs to be done.
Accessibility widgets allow visitors to adjust certain display preferences and help them monitor the status of a website.
Compliance, however, stems from correcting the code at the source: the 2026 AgID Guidelines recommend reserving these tools for specific cases, and the European Commission has indicated that correction at the source is the way to meet the EN 301 549 standard.
It’s important to understand this distinction before signing a contract. There are offers on the market that present the installation of a script as a complete solution: the site remains unchanged beneath the surface, and the barriers stay where they are.
The European Disability Forum and IAAP have issued a joint statement on this issue, and AgID has clarified that the remediation requires human intervention.
Our approach combines both of these elements. We are an authorized UserWay partner—one of the world’s most widely used platforms for digital accessibility management—and we use it for what it does best:
Next, we make changes to the code. On 90 percent of the websites we’ve worked on, we achieved compliance by correcting the HTML that was causing the barrier right at the source.
This way, the technology does what it’s designed to do, the correction remains structural, and the site remains free of the tracking techniques that the guidelines call for caution regarding.
Accessibility and usability address two different questions that lead in the same direction.
Accessibility refers to whether everyone can use the site. Usability refers to how easy and enjoyable it is to use.
A contact form with clear labels, a logical order of fields, and understandable error messages benefits everyone: it helps users who navigate with a screen reader and, at the same time, reduces abandonment rates for everyone else.
That is why an accessibility improvement almost always results in a measurable increase in conversion rates.
This topic is explored in greater depth on the page dedicated to the article: Website user experience →
The process consists of four stages.
Those who prefer to start with an overall technical overview can begin with a technical analysis of the site →
Making a website accessible means addressing different needs with specific solutions. People who are blind or visually impaired use screen readers and need alternative text for images, adequate contrast, and a well-organized semantic structure.
People with mobility impairments often navigate using only the keyboard and need commands that can be accessed without a mouse.
People with hearing impairments benefit from captions and transcripts, while those with cognitive challenges appreciate clear language and straightforward processes.
Designing to accommodate this variety of needs broadens the audience your site can reach and makes the experience more robust for every visitor. An accessible website welcomes everyone.
The accessibility statement is the public document through which an organization discloses the accessibility status of its website or app.
It indicates the level of compliance achieved, lists the content that still needs to be updated along with the reasons why, and provides a feedback channel for users.
It is prepared using the template provided by the Agency for Digital Italy and is updated annually.
For the public sector, this requirement has been in place for years. For private entities covered by the decree, the declaration will become mandatory starting in September 2025, with annual updates.
One point deserves attention: the declaration describes the actual condition of the site. Claiming a higher level of compliance than is actually the case exposes one to a twofold risk—both formal and reputational.
It is therefore advisable for the report to be issued after the audit and to describe precisely what still needs to be done.
Starting in 2026, it will also include a statement confirming the absence of tracking techniques that could be used to infer a disability.
The cost of making accessibility modifications depends on five factors:
A preliminary assessment makes it possible to determine the scope of the project before beginning.
Two examples illustrate the difference between the two cases.
That is why the inspection always comes before the estimate.
Who is designing a new website is in the best position: building an accessible site from the start costs a fraction of what it costs to fix it later, and this applies even during the website development phase.
The method remains the same; what changes are the questions people ask, the channels they use, and the timing of their decisions. These are the four areas where we have the most expertise.
Accessibility involves code, design, and content all at once. When these three components are handled by different vendors, fixes become a never-ending cycle: the theme is fixed, but new content reintroduces the same barriers.
At Factory Communication, accessibility is an integral part of our work on the website.
We develop and maintain our clients’ websites, so compliance is built into the publishing process and remains part of it.
Those who update the website receive the necessary training, because an accessible website is an ongoing practice rather than a one-time goal.
UserWay’s authorized partner status adds a world-class platform for continuous scanning and monitoring to this work, while the fixes remain where they produce consistent results: in the website’s code.
The same logic applies to maintenance: the support and maintenance of WordPress sites includes periodic checks of accessibility.
We improved the accessibility of 10 websites belonging to the Heineken Italia group —including Birra Moretti, Birra Messina, Birra Dreher, and Birra Ichnusa —helping them achieve WCAG Level AA compliance, the standard required by European regulations.
The project combined continuous scanning on the UserWay platform—of which we are an authorized partner—with corrective actions to the code and content that ensured compliance.
Each site had its own strong and recognizable visual identity: some traditional color combinations fell short of the required contrast threshold, and the solution was found by adjusting the text colors while retaining the institutional colors in the decorative elements.
Working on well-known brands and multiple websites simultaneously has allowed us to establish a replicable method that can be applied to organizations of all sizes seeking to achieve compliance within predictable timeframes and at predictable costs.
This requirement applies to businesses that offer digital products or services to consumers and exceed at least one of the following thresholds: ten employees or two million euros in annual revenue. Micro-enterprises that provide services—that is, those with fewer than ten employees and whose combined revenue does not exceed two million euros—are exempt. The provisions take effect on June 28, 2025.
A widget offers visitors certain display preferences and helps monitor the site’s status. Compliance, however, stems from correcting the source code: the 2026 AgID Guidelines reserve these tools for specific interventions and require verification that they respect the privacy of people with disabilities. The path to achieving this result lies in HTML.
Legislative Decree 82/2022 provides for administrative penalties ranging from 5,000 to 40,000 euros for violations of accessibility requirements. For companies with an average annual revenue exceeding 500 million euros, the Stanca Law imposes a penalty of up to 5 percent of revenue. The regulation adopted by AgID in May 2026 sets out the process: first, a collaborative phase with the company; then, any necessary document reviews and on-site inspections, with the opportunity to submit comments; and the penalty is imposed only at the end of the process.
The Web Content Accessibility Guidelines are the W3C’s international guidelines, organized into three levels: A as the baseline, AA as the standard required by Italian and European regulations, and AAA as the level of excellence. The AgID Guidelines adopted in 2026 establish mandatory compliance with levels A and AA of WCAG 2.1. The European update that will make WCAG 2.2 a mandatory standard is currently being adopted and adds six criteria to the same two levels.
Accessibility refers to the ability of all people, including those with disabilities, to use the website. Usability refers to how easy and enjoyable it is for anyone to use the website. The two aspects reinforce each other: an accessible website is almost always more usable as well.
The audit combines three approaches: automated tools, which detect about one-third of the barriers; manual reviews of the code and content; and testing with assistive technologies such as screen readers. The result is a list of issues classified by severity, with a reference to the corresponding WCAG criterion.
Yes, indirectly. An accessible website has a correct semantic structure, a consistent heading hierarchy, alt text for images, and clear navigation—elements that search engines interpret as quality signals. Accessibility and technical SEO share many of the same best practices.
In addition to people with visual, hearing, mobility, or cognitive disabilities, an accessible website improves the experience for older adults, those using slow internet connections or outdated devices, and those accessing the site under challenging conditions.
It is estimated that there are approximately 1.3 billion people with disabilities, representing 16 percent of the world’s population—or one in six people.
Finding out where your website stands takes just a few hours of analysis and completely changes the picture: some discover they’re almost compliant, while others find they need to map out a plan. In both cases, you make decisions based on the data.
Let’s discuss this together: we’ll review your website, tell you where it stands in relation to the requirements, and identify which actions are a priority.
