Legal framework

Accessibility statement in Italy: which businesses are affected?

Does an Italian company need to publish an accessibility statement on its website? The answer depends on which rules apply to it: the AgID procedure and the obligations arising from the European Accessibility Act are not the same. In either case, publishing a statement is not enough if its content does not reflect the service provided.

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The short answer

Not all Italian companies are required to publish the same “accessibility statement.” To determine what to publish, you must distinguish between the statement required under Legge 4/2004 and the accessibility information required for certain products and services under Decreto legislativo 82/2022, which transposes the European Accessibility Act. The company’s scope, the nature of the service and the applicable law determine the form and content of the publication.

Two legal frameworks that should not be conflated

The Italian expression “dichiarazione di accessibilità” refers, in particular, to a declaration governed by Legge 4/2004, known as “Legge Stanca,” and the procedures published by the Agenzia per l’Italia Digitale, or AgID. This framework should not be treated as a synonym for the obligations created by the European Accessibility Act. Research into the accessibility of company websites may lead to both sets of rules, even though they address different questions.

Directive (EU) 2019/882, known as the European Accessibility Act, was transposed into Italian law by Decreto legislativo 82/2022. It applies to defined categories of products and services made available to consumers. For covered services, its Annex V requires information that makes it possible to assess how the service meets the applicable accessibility requirements. This information appears in the terms and conditions or an equivalent document, in an accessible form.

It would therefore be misleading to claim that a company complies with the European Accessibility Act simply because it displays a declaration in the AgID format. The reverse would be equally unsound: a page explaining the accessibility of a covered service does not automatically replace a declaration required under another regime. Each obligation must be identified separately before choosing a document template.

• Legge 4/2004: check whether the organization falls within its scope and, if so, which declaration procedures apply to it.
• Decreto legislativo 82/2022: check whether the company provides a product or service in one of the specified categories.
• For each applicable law: distinguish the obligation to make the service accessible from the obligation to publish information about its accessibility.

Which businesses need to assess the European Accessibility Act?

The first criterion is neither the sector in which a business says it operates nor whether it has a website. It is the nature of the product or service offered. Services covered by Directive (EU) 2019/882 include certain consumer banking services, e-books and dedicated software, and e-commerce services. Decreto legislativo 82/2022 implements these provisions in Italian law.

For e-commerce, the issue is not limited to a page describing the business. It concerns a service provided at a distance, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. An ordering process may therefore require a different assessment from a purely informational website. Classification depends on the service actually offered, not on what the website is called.

Microenterprises that provide services benefit from an exemption under the directive. This does not mean that every small business is automatically exempt: the legal definition of a microenterprise and the nature of the activity concerned must be checked. Provisions concerning a fundamental alteration of the service or a disproportionate burden also require an assessment within the prescribed framework; a statement on the website alone is not enough to establish that they apply.

The requirements applicable to covered services take effect on 28 June 2025, subject to the transitional provisions in the legislation. The date alone does not determine whether a service is covered, how an existing contract is treated, or how equipment already in use is treated. For a specific case, it remains necessary to consult Decreto legislativo 82/2022 and its transitional provisions.

The right starting point for a business

Describe the service from the consumer’s perspective: what they can do, when a contract is concluded and which interfaces are involved. Then compare that journey with the categories in the legislation. This approach avoids assuming that a business has a publication obligation simply because it owns a web domain, or dismissing the issue because the service is also provided offline.

When does the AgID procedure apply?

AgID, the Italian digital authority, publishes guidance and procedures concerning the “accessibility statement” under Legge 4/2004. For a private company, the question is whether it is actually subject to that framework. This cannot be determined by copying another website’s statement or by assuming that the European Accessibility Act’s entry into force extends the AgID procedure to all companies.

The scope of the AgID statement must be checked against Legge 4/2004 and the official instructions for the organisation’s category. This check is particularly necessary before making any claim about a public body: its obligations cannot be inferred from those of a private company. This article therefore does not present the AgID procedure as a universal requirement for Italian websites.

If the organisation is subject to this procedure, it must use the applicable process and required sections rather than a free-form text labelled a “statement”. A statement concerning a particular website must describe that website and its actual state. It does not constitute a general finding about all the applications, domains or services of a group unless its scope actually covers them.

If the organisation is not subject to this procedure, it must still consider Decreto legislativo 82/2022. A service may be subject to requirements arising from the European Accessibility Act without filing an AgID statement being the appropriate response. This distinction is decisive when choosing the right form of publication.

What must the published information say about a covered service?

Annex V to Directive (EU) 2019/882 starts with the service, not a compliance statement. The service provider must supply accessible information describing the service and how it works, then explain how the applicable accessibility requirements are met. The text also calls for information showing that the provision and monitoring of the service maintain that compliance. The Italian implementing law must be consulted to apply these requirements to a particular situation.

A statement such as “website compliant with accessibility rules” leaves several questions unanswered. Which service does it cover? Does it include account creation, browsing a catalog, and entering into a contract? Which channels are covered? Useful information sets out a clear scope and describes how to access the service without claiming qualities that have not been verified.

• Describe the service concerned and the steps needed to use it.
• Explain the accessibility features relevant to those steps in understandable language.
• State how the company assesses and monitors the accessibility of the service.
• Keep the information consistent with the interfaces and user journeys actually offered.

The form matters too. Under Annex V, the information appears in the terms and conditions or an equivalent document and is made available in accessible formats. A standalone page that is hard to find or consult does not solve the problem merely by existing. The chosen format must allow the people concerned to access information about the service they wish to use.

This content must not be mistaken for certification. Citing the WCAG, announcing an intention to make corrections, or adding a contact address is not enough. Each of these elements may have a place, but none replaces an accurate description of the service, the requirements that apply to it, and how compliance with them is monitored.

Why publication also entails responsibility for the substance

The easiest mistake is to treat the declaration as an editorial deliverable completed when it is published. Yet its content concerns a service that can change: navigation, forms, authentication, payment or support. If the interface changes while the published information stays the same, that discrepancy becomes a reliability problem in its own right.

Automated analysis can help identify testable issues on pages and track how they change. On its own, it cannot establish the accessibility of an entire user journey or determine all of a company’s legal obligations. Manual testing, particularly with assistive technologies and at the steps consumers actually use, remains necessary to examine what a scan cannot establish.

The Inclaria 2026 study shows why a broad claim should be checked against actual user journeys: 94.5% of the 55 websites analysed in its French e-commerce sample had at least one critical or serious accessibility failure. This finding concerns French websites selected for the study. It measures neither the Italian market nor the proportion of companies subject to Decreto legislativo 82/2022.

A credible publication distinguishes what has been verified from what remains to be examined. It avoids absolute guarantees when limitations are known, ties findings to specific pages or functions, and provides a way to address reported difficulties. This discipline primarily protects the people who use the service: they need usable information, not a decorative promise.

A method for publishing without losing track of checks

Start with a brief map of the services, interfaces and legal provisions that may apply. For each service, record why it was included in or excluded from the scope of the review. This record makes it easier to have the legal classification reviewed without asking a developer to resolve a legal question alone.

Next, examine the user journeys necessary to use the service. Combine automated checks with manual reviews, then record the issues found, their impact and the proposed fixes. The public-facing document should remain readable; detailed technical evidence can be kept in internal records. The aim is to link every published claim to an identifiable check.

Finally, draft the content within the appropriate framework. If the AgID procedure applies to the organization, follow its official requirements. If a service falls under Decreto legislativo 82/2022, prepare the required information about that service in the terms and conditions or an equivalent accessible document. Where multiple obligations apply, address each one explicitly rather than presenting a single document as an automatic response to every law.

Plan a review whenever the service or its user journeys change significantly. The person responsible for public-facing content should be able to see what changed, what was retested and whether any wording needs to be corrected. This approach keeps the published information up to date without suggesting that a one-off check settles accessibility for good.

This content is for informational purposes and does not constitute legal advice. To determine a company's obligations, including whether it is subject to the AgID procedure or qualifies for an exception, have the specific circumstances reviewed by a lawyer qualified in Italian law.