The AgID Accessibility Guideline

The obligations of the European Accessibility Act (EAA) have applied to private companies in Italy since 28 June 2025. What changed in 2026 is not the rules themselves, but the fact that they can now be enforced. With the publication of the AgID Guidelines 38/2026 and the launch of a public complaints platform, digital accessibility in Italy has moved from a written obligation to something that can be checked, contested, and sanctioned.

If your organisation offers digital services to consumers in the Italian market, this is a short, practical explainer of what the guidelines say, who they apply to, and how the process works.

What are the AgID accessibility guidelines?

Since 28 June 2025, Legislative Decree 82/2022 — Italy's transposition of the EAA — has required private companies to make their digital services accessible. On 4 March 2026, the AgID Guidelines 38/2026 made those obligations concrete: they define the technical standards to follow and the framework for penalties, turning compliance from a principle into a matter of practical verification and real inspections.

The most significant shift is institutional. AgID (Italy's Agency for Digital Italy) has moved from being a designated authority to an operating one. For the first time, private companies can receive formal complaints, requests for documentation, and penalties — without prior warning.

A short timeline helps put this in context:

• 28 June 2025 — EAA obligations begin to apply to private companies.

• 4 March 2026 — AgID Guidelines 38/2026 published.

• 11 March 2026 — AgID's online complaints platform goes live.

What the guidelines clarify

Two elements of the guidelines are worth understanding early, because they shape how compliance is demonstrated in practice.

Control sheets (schede di controllo). These are the main reference points for verifying the conformity of websites and apps. They are not, strictly speaking, mandatory — but they are the instrument used during inspections. Completing them and keeping them properly is what gives a company documented proof that it has done the work.

Disproportionate burden (onere sproporzionato). Companies can invoke this exemption when the cost of adaptation would be genuinely excessive. It requires a documented assessment demonstrating that adaptation is realistically impossible, and that assessment must be retained for five years.

Who has to comply?

Legislative Decree 82/2022 applies to private companies that offer digital services to consumers in specific sectors. Importantly, if a service is used by both consumers and professionals, it must be fully compliant. The sectors covered include:

• E-commerce — online sales to consumers: the website, the app, the purchase flow, account management, and payments.

• Banking and financial services — home banking, payment apps, investment platforms, account management, and electronic money.

• Passenger transport — online ticketing, booking apps, and real-time information for air, rail, bus, and maritime travel.

• Telecommunications — consumer internet services, VoIP, messaging apps, and access to communication networks.

• Audiovisual media — video content platforms, including electronic programme guides (EPGs), subtitles, and audio descriptions.

• E-books and reading software — digital book distribution services and reading software, including mobile e-reader apps.

Microenterprises are generally outside the scope of these obligations.

How reporting works

Since 2026, anyone can report a digital service that presents accessibility barriers to AgID. The procedure is online, free, and open to any user.

Crucially, the report does not originate from AgID — it comes from users, who now have a formal channel to assert their rights. The report reaches the company directly, and the company must respond with a remediation plan within 30 days. Silence or a missing response is what triggers the sanctioning procedure.

The reporting flow is straightforward:

1. The user accesses the AgID portal and completes the reporting form.

2. They identify the digital service and describe the barrier encountered, and on which channels.

3. AgID forwards the complaint to the provider and opens the procedure.

The penalties

For small and medium-sized enterprises, penalties range from a minimum of €2,500 to a maximum of €40,000 per individual violation. For companies with revenue above €500 million, the ceiling is set at 5% of average three-year turnover.

Four practical steps toward compliance

Compliance is less about reacting to a complaint and more about approaching the requirements in a planned way. A sensible sequence looks like this:

1. Check your scope. Confirm whether your digital services fall within the scope of Legislative Decree 82/2022. If you offer services to consumers in the covered sectors — and you are not a microenterprise — you are subject to the obligations.

2. Run a gap analysis. A thorough evaluation identifies the digital barriers that prevent people from using your services, turning uncertainty into a clear, actionable picture.

3. Document and sign. Every assessment — conformity, disproportionate burden, substantial modification — must be formalised, digitally signed, timestamped, and retained for at least five years.

4. Adapt structurally. An Accessibility by Design approach builds inclusive services from the ground up, making accessibility an intrinsic capability of your team rather than a one-off fix.

What happens after a complaint

AgID handles complaints in stages. First, there is a formal assessment and contact with the provider. This opens a dialogue phase, in which the provider responds with documentation. If that documentation is unconvincing or does not exist, corrective measures, penalties, or service suspension can follow.

In short

The rules were already in place; what arrived in 2026 was the machinery to enforce them and a channel for users to act. For any organisation providing digital services to consumers in Italy, the practical takeaway is to understand where you stand, document it properly, and treat accessibility as an ongoing capability rather than a deadline to meet under pressure.