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European Directives (2016/2102 and 2019/882)

Directive 2016/2102: "of the European Parliament and of the Council of 26 October 2016 on the accessibility of public sector bodies' websites and mobile applications." Directive 2019/882: "of the European Parliament and of the Council of 17 April 2019 on accessibility requirements for products and services." EN 301 549 is a European technical standard produced by the European Telecommunications Standards Institute (ETSI), the E.U. agency that regulates the digital sphere. EN 301 549 defines the official standards for Web accessibility in Europe.

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When did the EAA (2016/2102) come into force?

The Digital Administration Code (DAC) has enshrined in the Italian legal system the principle and implementation of accessibility of all content published on institutional websites to enable every citizen, especially people with disabilities, to use them.

With a decree approved in the Council of Ministers at the proposal of the Prime Minister's Office and the Minister for Public Administration, Directive (EU) 2016/2102 of the European Parliament and the Council of October 26, 2016 was implemented.

The actions required for adaptation concern, in particular:
  • the "disproportionate burden," a principle according to which requests for accessibility of data held by the PA must be evaluated taking into account the impact and exigibility from an organizational, technological and financial point of view;
  • the "feedback mechanism," by which anyone, in accordance with the accessibility principles and accessibility requirements dictated by the guidelines, can: notify providers of any defects in information systems, including websites and mobile applications; request information that is not accessible.
Response to legitimate and reasonable requests will be ensured by the possibility of filing complaints with the "digital ombudsman."

What are the requirements of the EAA?

The EAA does not define specific accessibility standards or compliance requirements. This is because it wants to leave flexibility within the law.

The EAA's official Fact Sheet states that the law "will not impose detailed technical solutions that tell how to make" a site compliant, although general requirements and non-binding examples can be found within the legislation.

For example, the EAA requires that no website or digital service be limited to a single mode of interaction, so audio content must also be accessible through captions and text written through a screen reader.

To which products and services does the EAA apply?


The EAA is deliberately designed so that it is not a general law that affects all industries. The EAA clearly defines which categories of products and services are subject to the new law. These include:
  • Computers and operating systems
  • Telephone services and related equipment
  • Audiovisual media services, such as television broadcasting and related consumer equipmentServices related to air, bus, rail and other passenger transportation
  • Services related to air, bus, rail and other passenger transportation
  • Banking services
  • eBooks
  • eCommerce
Although originally aimed at public and government groups, it also covers private businesses. Companies providing services for government agencies in Europe will need to be sure that their accessibility standards are adequate. The EAA also requires that all online business services be accessible to people with disabilities.

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