Edited by Paola Furiosi and Francesca Caliri
The entry into force of the obligations set out by the European Accessibility Act (Directive (EU) 2019/882, “EAA”) is now imminent: as of 28 June 2025, all companies operating in the relevant sectors will be required to ensure the full accessibility of their digital products and services, in accordance with Legislative Decree 82/2022, which transposed the directive into Italian law.
Objectives and Scope of Application
The European Accessibility Act represents one of the European Union’s most ambitious initiatives to break down digital barriers and ensure that technology is a tool for empowerment rather than social exclusion. The aim is to strengthen the rights of persons with disabilities by imposing new accessibility requirements on a wide range of products and services in sectors where digitalisation has a direct impact on quality of life and personal autonomy, including:
- computers and mobile devices;
- ATMs, ticketing machines, and self-service terminals;
- eBooks and eReaders;
- banking and financial services;
- public transport services;
- telecommunications services;
- eCommerce.
The above regulatory obligations will be subject to different deadlines. Specifically, they will apply from 28 June 2025, exclusively to all new products and services, while products already placed on the market before that date may continue to be sold until 28 June 2030.
The same deadline of 28 June 2030 will also apply to services already provided before 28 June 2025, unless there are substantial changes that require immediate compliance.
Accessibility Requirements: What Changes in Practice for Businesses
With the imminent application of the legislation, companies are called upon to act promptly and with foresight, sometimes moving towards a profound cultural and organisational change.
It is, in fact, essential to initiate a thorough assessment of the compliance of their digital assets, identifying any critical issues and planning the necessary interventions. It is not only a matter of adapting websites or mobile applications, but of rethinking the entire user experience from the perspective of universal accessibility. In this regard, the requirements set out by the legislation are detailed and are intended to ensure that information relating to products and services is always clear, easily understandable, and perceivable by all users, regardless of their abilities.
This means, for example, using appropriate fonts and sizes, or ensuring sufficient colour contrast and allowing for the adjustment of spacing between letters, lines, and paragraphs. Information must also be presented through alternative sensory channels to meet the diverse needs of users. Where necessary, alternative presentations of content must be available, so as not to exclude anyone from understanding the content itself. In general, accessibility must be ensured consistently across all digital channels, from websites to mobile apps, up to the most complex online services.
It is also essential to review existing agreements with suppliers and partners, which will require the inclusion of specific clauses governing compliance with the accessibility requirements provided by law.
Staff training also plays a key role in complying with the relevant legislation: all teams involved in the development, management, and communication of digital products and services should be made aware of the new rules and best practices in the field of accessibility, and – in this context – constant regulatory monitoring and collaboration with industry experts can make the difference in ensuring an effective and risk-free transition.
Sanctions, Risks, and Opportunities for Businesses
Failure to comply with accessibility requirements will result in administrative penalties being imposed by the competent national authorities (in Italy, the Agency for Digital Italy, “AGID”), as well as requests for non-compliant products to be modified or withdrawn from the market and corrective measures being taken by the competent authorities.
It should be noted, however, that based on the provisions of the Italian Consumer Code (Legislative Decree No. 206/2005), non-compliance could be considered an unfair commercial practice, especially if it prevents a consumer with disabilities from making informed choices. In such cases, the penalties are particularly severe and can be as high as €10 million, depending on the severity and duration of the violation.
In addition to the economic risk, companies must also consider the reputational impact, especially since the new legislation provides for a consumer reporting mechanism, with potential negative impacts on user confidence, in a context where public and institutional attention to digital inclusivity is constantly growing. Today more than ever, attention to inclusion and social responsibility is a distinctive (and sometimes essential) factor in the eyes of customers, business partners, and investors.
That said, compliance with accessibility standards should not be seen merely as a regulatory obligation to be fulfilled, but also as an opportunity. Making products and services accessible means expanding one’s potential market, reaching an increasingly broad and diverse audience. Moreover, companies that stand out for their focus on accessibility can position themselves as leaders in responsible innovation, anticipating trends and community expectations.
In conclusion, compliance with accessibility obligations represents a strategic investment that can generate tangible benefits not only for businesses and consumers, but also for society. The deadline of 28 June 2025 will mark the beginning of a new era for the Italian and European digital market: being ready for this change is now more than ever a priority.
Let’s Talk
Per una discussione più approfondita ti preghiamo di contattare:
Contatta Andrea Lensi Orlandi – Partner, PwC TLS Avvocati e Commercialisti
Contatta Paola Furiosi – Director, PwC TLS Avvocati e Commercialisti