EAA in Italy (D.Lgs. 82/2022): what your online store must do
In short
Legislative Decree no. 82 of 27 May 2022 (decreto legislativo 82/2022) is the law that brings the European Accessibility Act into force in Italy. It has applied to private economic operators since 28 June 2025. If you sell online to consumers in Italy — even from outside the country — you are very likely covered. Key points:
- e-commerce is named explicitly ("servizi di commercio elettronico", art. 1.3.f);
- a non-compliant service faces an administrative fine of €5,000 to €40,000 (art. 24);
- the technical reference standard is, in practice, EN 301 549 (which incorporates WCAG 2.1 level AA);
- the supervisory authority for services is AgID (Agenzia per l'Italia Digitale);
- you must publish accessibility information about your service (art. 12 / Allegato IV).
Italy is one of the largest e-commerce markets in the European Union. If you sell there, accessibility is no longer optional: Legislative Decree 82/2022 transposes the same European directive as the French and Spanish laws, but with its own fine scale, its own authority (AgID) and its own information duty. Here is what changes in concrete terms.
Which law: D.Lgs. 82/2022
The decreto legislativo 27 maggio 2022, n. 82 ("Attuazione della direttiva (UE) 2019/882 … sui requisiti di accessibilità dei prodotti e dei servizi") is the Italian transposition of Directive (EU) 2019/882 — the European Accessibility Act (EAA). It is the exact Italian equivalent of what Ordinance no. 2023-859 does in France: the same European obligation, implemented in national law. It was published in the Gazzetta Ufficiale no. 152 of 1 July 2022 and applies to products and services placed on the market from 28 June 2025.
The decree is a standalone text that sits alongside the "Legge Stanca" (law no. 4 of 9 January 2004) without repealing it: the two regimes coexist (more on this under sanctions). E-commerce is named explicitly: art. 1, paragraph 3, letter f) lists "servizi di commercio elettronico" among the covered services, alongside consumer banking, electronic communications, passenger transport, e-books and audiovisual media on demand.
The technical standard: EN 301 549 / WCAG 2.1 AA
The Italian decree does not reinvent the technical criteria. As everywhere in the Union, digital accessibility is assessed against the harmonised standard EN 301 549, which for the web incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, level AA. Following the harmonised standards whose references are published in the Official Journal of the European Union opens a presumption of conformity with the decree's requirements (art. 14).
In practice, the requirements are the same as in France or anywhere else in Europe: sufficient colour contrast, text alternatives for images, keyboard navigation, properly labelled forms, a page structure readable by assistive technology. For e-commerce, Allegato I (Sezione IV, letter f) additionally stresses the accessibility of identification, security and payment functions. A site already built to WCAG 2.1 AA satisfies the core of the decree.
How much: the sanctions regime (art. 24)
Monitoring of services falls to AgID (see below). Where there is a breach, it can require corrective measures and then impose an administrative financial penalty. Article 24 of D.Lgs. 82/2022 sets the brackets:
| Breach | Fine | Reference |
|---|---|---|
| Service not compliant with the accessibility requirements (substantive breach) | €5,000 – €40,000 | Art. 24, para. 1 |
| Failure to comply with the authority's orders / non-cooperation | €2,500 – €30,000 | Art. 24, para. 2 |
| Incomplete or untruthful information provided to the authority | €2,500 – €30,000 | Art. 24, para. 3 |
Beyond the fine, the most immediate lever is operational: AgID can require compliance and, in serious cases, order the prohibition of supply of the non-compliant service. For an online store, having your checkout obstructed on the Italian market often weighs more heavily than the size of the penalty itself.
Who enforces it? AgID
Supervision of the accessibility of services — and therefore of e-commerce — is entrusted to the Agenzia per l'Italia Digitale (AgID), designated as the vigilance authority by art. 21 of the decree. It receives reports, monitors services, requests documentation, can impose corrective measures and, in serious cases, prohibit the supply of the service; it also issues the implementing Linee Guida. (Surveillance of products falls to a separate authority, the competent ministry, under art. 17.)
An inspection can be triggered by a report — for example a person with a disability who cannot complete a purchase — just as much as by an own-initiative check.
The mandatory document: accessibility information (art. 12 / Allegato IV)
Beyond technical accessibility, the service provider must provide information about the accessibility of its service. This is the obligation in art. 12, whose content is detailed in Allegato IV of the decree: (1) a general description of the service in an accessible format, (2) the explanations needed to understand how it works, and (3) a description of how the service meets the applicable accessibility requirements. This information must be made public and kept up to date.
As in France, this document is immediately verifiable: an inspector does not need to audit dozens of technical criteria to note that it is missing. It is the easiest breach to establish.
The user's avenues of recourse
A user who hits a barrier has a multi-step path:
- first, the feedback mechanism that the operator must provide for reporting an inaccessibility;
- failing a satisfactory response, a report to AgID, the supervisory authority for services, which can open an inspection;
- in parallel, the ordinary judicial route, notably under the rules on non-discrimination of persons with disabilities.
For the business, the stakes are clear: each of these routes can bring your service to the authority's attention. Better to be compliant before the first report than after it.
The mistake to avoid: "one-click accessibility" overlays
Widgets such as accessiBe or UserWay promise automatic compliance through a single line of code. They do not make a site compliant. Their real effectiveness is disputed by disability organisations; in the United States, the FTC fined accessiBe one million dollars in 2025 over compliance claims found misleading. Above all, an overlay does not fix your site's source code and does not produce the accessibility information required by art. 12 / Allegato IV of the decree.
The defensible path is the opposite: audit the site, fix what can be fixed, and publish honest accessibility information that documents the real state and the action plan.
How to comply, in practice
- Audit. An automated technical scan (WCAG 2.1 AA) catches part of the non-conformities — contrast, image alternatives, structure, forms. It does not replace a full manual audit, but it establishes a factual, quantified baseline.
- Fix the priority items — often few in number and inexpensive (colour contrast, form labels, keyboard navigation).
- Publish the accessibility information (art. 12 / Allegato IV), with an accurate conformance status and the avenues of recourse.
- Keep it up to date: compliance degrades with every release. A periodic re-scan keeps you from drifting.
Check your exposure in 2 minutes
DeclareAccess scans one page of your site (WCAG 2.1 AA), sends you a quantified report of the non-conformities, then generates the ready-to-publish accessibility document — Italian ("Informazioni sull'accessibilità", art. 12 / Allegato IV), French (RGAA), Spanish (art. 13) or German (BFSG). Free audit, no credit card.
WCAG report by email within 1 business day.
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Frequently asked questions
I sell into Italy from abroad: am I subject to D.Lgs. 82/2022?
Yes, very likely. The obligation follows the market you target, not where your company is registered. As soon as you offer your products or services to consumers in Italy, that activity falls under D.Lgs. 82/2022 for the Italian market — just as it falls under each other country's law for the markets it serves. A multi-country shop accumulates the corresponding national regimes.
Does Italian law require anything different from WCAG?
Not in technical substance. Conformity is presumed for a service that follows the harmonised standards published in the Official Journal of the EU (art. 14); for the web, the relevant standard is EN 301 549, which incorporates WCAG 2.1 level AA. A site already built to WCAG 2.1 AA satisfies the core requirements. The difference lies in the mandatory document (accessibility information, art. 12 / Allegato IV), the authority (AgID) and the Italian sanctions regime.
How much is the EAA fine in Italy?
Article 24 of D.Lgs. 82/2022 sets administrative fines of €5,000 to €40,000 for a service that does not meet the accessibility requirements, and €2,500 to €30,000 for failing to comply with the authority's orders or providing untruthful information. The "5% of turnover" ceiling that circulates online is not in art. 24: it comes from the Legge Stanca and applies only to very large operators (over €500M average turnover) after an unheeded formal notice from AgID.
Is my small online store covered?
If you have 10 or more people, or more than €2M in annual turnover or balance-sheet total, yes. Microenterprises below both thresholds are exempt from the decree for the services they provide (art. 3, para. 3), but the exemption does not work the same way for products. When in doubt, an audit gives you a factual answer on the state of your site, regardless of status.
Who checks the accessibility of my online store in Italy?
AgID (Agenzia per l'Italia Digitale) is the vigilance authority for services under art. 21 of the decree. It receives reports, monitors services, can require corrective measures and, in serious cases, prohibit the supply of a non-compliant service. Surveillance of products falls to a separate authority (the competent ministry) under art. 17.
Does an overlay (accessiBe, UserWay) make me compliant in Italy?
No. An overlay adds a widget whose effectiveness is disputed, does not fix the source code and does not produce the accessibility information required by art. 12 / Allegato IV of D.Lgs. 82/2022. The compliant approach is to audit the site, fix the non-conformities and publish honest accessibility information.