Informational website
It describes the business and services and collects a general enquiry. It does not automatically become e-commerce, but what happens after contact must be considered.
Guides
Website accessibility: who must comply and what it really takes
Not every website has the same legal duties, but organisations that fall within scope cannot solve accessibility by installing a widget. Code, content and complete processes must work for people with disabilities.
Short answer
Italy does not have one blanket obligation applying to every private website. The organisation, service, audience and business size all matter. Public bodies, very large private organisations and providers of specific services — including e-commerce — can fall under different regimes. Microenterprises providing services are exempt from the duties in Legislative Decree 82/2022, but the exemption must be checked against the real case. A preference panel can help users; it does not replace a WCAG evaluation.
Gian Luca Partengo
Web developer since 1995 · bespoke websites · Updated
Does your website have legal duties? You cannot tell from its homepage
“Must every website be accessible?” is the wrong question. The answer depends on the organisation and service, not simply on owning a domain.
- 01Identify the service provider: public body, very large private organisation, SME or microenterprise
- 02Define what the website lets users do: obtain information, book, buy, pay or use a regulated service
- 03Check the applicable regime: Law 4/2004, Legislative Decree 82/2022, sector rules or contractual requirements
- 04Set the scope, technical standard, complete processes, documents and maintenance that must be covered
Law 4/2004, the EAA and AgID Guidelines are not the same thing
The Italian framework combines different rules and audiences. Reducing it to “every website had to comply from 2025” is inaccurate.
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2004
Law 4/2004, known as the Stanca Law
It was introduced to improve access to information technology, particularly for people with disabilities. It covers public bodies and other entities identified by the law.
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2020
Extension to very large private organisations
Duties were extended to organisations providing public-facing services through websites or apps with average turnover above €500 million over the previous three years.
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2025
The European Accessibility Act starts applying
From 28 June 2025, Legislative Decree 82/2022 applies accessibility requirements to defined products and service categories placed on the market, including e-commerce services.
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2026
AgID Guidelines for services
Guidelines adopted on 4 March 2026 clarify evaluation, requirements, public information and oversight for services covered by the decree.
The rule to remember
28 June 2025 did not suddenly make every website subject to the same duties. It introduced requirements for defined products and services, so the case must be classified correctly.
Who may have website accessibility duties
This table supports an initial review. It does not replace a check of the organisation, service and any sector-specific rules.
| Organisation or service | Main reference | When it matters | First action |
|---|---|---|---|
| Public bodies and equivalent entities | Law 4/2004 and related rules | Websites, apps and digital services within the public-sector scope defined by law | Check requirements, declaration, feedback and periodic updates |
| Private organisations above €500m | Article 3(1-bis), Law 4/2004 | Public-facing services through websites or apps and average turnover above the three-year threshold | Define scope and declaration and monitoring duties |
| EAA service providers | Legislative Decree 82/2022 | Electronic communications, media, transport, consumer banking, e-books and e-commerce | Check the service, market, consumer, date and any exemptions |
| Other private websites | No blanket automatic obligation | Informational or professional websites outside the scopes above, unless another constraint applies | Adopt good practice and check contractual or sector duties |
Procurement, contracts, regulated sectors and client requirements can create additional duties. This table is not legal advice.
When a website counts as an e-commerce service
Online payment is an obvious signal, but it is not the only one. The European definition focuses on concluding a contract with a consumer.
Booking or ordering
It may fall within scope if the flow lets the consumer enter a contractual commitment, even where payment is collected later.
Shop and checkout
Catalogue, basket, customer details and payment form a complete process that must be evaluated from the first step through confirmation.
“E-commerce” is a legal definition here, not merely a commercial or technical category.
Microenterprises: when the exemption applies
AgID Guidelines state that microenterprises are exempt from the service accessibility duties in Legislative Decree 82/2022. This does not mean every small business is exempt from every rule.
A microenterprise employs fewer than 10 people and has annual turnover or an annual balance-sheet total no higher than €2 million. Both parts of the definition must be checked using the correct data.
The exemption concerns microenterprises providing services within the EAA scope. It does not remove duties that may arise under Law 4/2004, regulated sectors, procurement, contracts or the role performed in a project.
For businesses that are not exempt, fundamental alteration and disproportionate burden are not shortcuts: they require a reasoned, documented assessment under the decree.
People employed
The first threshold in the European microenterprise definition.
Turnover or balance sheet
The financial threshold concerns annual turnover or the annual balance-sheet total.
Scope of the exemption
The EAA exemption covers microenterprises that provide services.
WCAG: what making a website accessible really means
The W3C Web Content Accessibility Guidelines organise accessibility into testable requirements. They are not a plugin and cannot be fully evaluated by one automated scan.
Perceivable
Content and controls must be presented in forms people can perceive, including alternatives, contrast, captions and adaptability.
Operable
Navigation and components must work by keyboard, show focus and avoid impossible movement or timing requirements.
Understandable
Copy, navigation, instructions, errors and behaviours must be clear, consistent and predictable.
Robust
Code must communicate name, role, value and state correctly to browsers and assistive technologies.
| Level | Meaning | Practical use |
|---|---|---|
| A | Fundamental Level A criteria | Minimum baseline, not sufficient as a modern general target |
| AA | All Level A and AA criteria | The most common technical target for websites and services |
| AAA | All Level A, AA and AAA criteria | Not recommended as a general requirement for entire websites |
For the websites I build, WCAG 2.2 AA is the technical target. A legal evaluation must still map the project to the standard and version required by the applicable regime.
Accessibility widgets: useful preferences, useless excuses
A panel can enlarge text, improve readability or reduce animation. It does not automatically repair the underlying website.
“The law requires an accessibility button”
No. The rules require accessible services and information; they do not prescribe one universal sidebar.
“The widget is installed, so the website conforms”
No. A panel does not automatically repair HTML, focus order, forms, checkout, documents, media or content.
“The automated test scored 100, so we are done”
No. Many criteria require human judgement, keyboard use and testing with assistive technologies.
“Accessibility only means screen readers”
No. Accessibility covers visual, auditory, physical and cognitive needs and different combinations of disability.
“Checking the homepage is enough”
No. Pages, states and complete processes must be evaluated — including basket, checkout and confirmation in an online shop.
“A high-contrast theme fixes the colours”
Only if every combination, component and state has actually been measured. A menu label is not evidence.
The correct distinction
A conforming website may have no widget at all. A non-conforming website remains non-conforming even with a widget. The panel is an additional preference, not a certification.
What a serious accessibility evaluation must check
Automated tools find only some problems. A complete evaluation combines code inspection, manual tests, assistive technologies and real processes.
Structure and content
- Headings, landmarks and logical order
- Relevant text alternatives
- Language of page and parts
- Semantically correct tables and lists
- Documents and media within scope
Keyboard and focus
- Every action available without a mouse
- Coherent focus order
- Focus always visible and not obscured
- No keyboard traps
- Correct dialogs, menus and components
Visual presentation and motion
- Contrast for text, controls and states
- Zoom and text resizing
- Reflow without losing functions
- Target size and spacing on mobile
- Reducible motion and no dangerous flashing
Forms and processes
- Labels, instructions and required fields
- Errors identified and associated with fields
- Status messages announced correctly
- Usable authentication and payments
- The complete process tested from start to finish
Accessibility, SEO and GEO help each other, but they are not synonyms
Clearer markup is easier for browsers, assistive technologies, search engines and AI systems to interpret. That does not mean conformance guarantees rankings or citations.
Descriptive headings, text in real HTML, understandable links, text alternatives and semantic relationships reduce ambiguity. They help people and also make content easier for machines to interpret.
Performance, security, structured data and authority remain separate disciplines. A website can meet many WCAG criteria and still have weak SEO; it can also rank while maintaining serious barriers for users.
The advantage of custom code is control: fewer generic layers, testable components and the ability to repair the source of a problem instead of covering it with an overlay.
Also read how to make a website citable by AI systems, the difference between WordPress and a custom website and website security.
Where the problem is solved
HTML semantics
Overlaynot rewritten
COREat source
Forms
Overlaypartial
COREdesigned
Processes
Overlaynot validated
COREtested
Maintenance
Overlayreactive
COREtracked
Qualitative comparison: accessibility always depends on the actual project and the evaluations performed.
Accessibility in bespoke websites: what is included and what the full package costs
The technical baseline is not sold as an extra. The paid service covers scope, documented evaluation, remediation and maintenance.
Included with websites
Baseline accessibility
Every website I build starts from an accessibility-aware CORE and includes local preferences. Both are checked again after the project’s branding, content and functions are applied.
- Semantic structure, landmarks and skip link
- Keyboard navigation and visible focus
- Labelled forms and reduced-motion support
- Removable Accessibility preferences panel
- Automatic, removable light/dark theme
Optional service
WCAG accessibility conformance package
A documented technical programme targeting WCAG 2.2 AA over the agreed scope. It is not a version of the panel and does not end with an automated scan.
- Analysis of applicability, scope and processes
- Agreed technical and content remediation
- Automated, manual and assistive-technology testing
- Report, evidence and regression log
- Maintenance and revalidation during the first 12 months
| Service | Indicative scope | Price before tax |
|---|---|---|
| Baseline accessibility | Included in website packages | Included |
| WCAG package | Small, monolingual website with contained scope | From €1,800 |
| Extended WCAG package | Pro, multilingual or with complex processes | From €2,400 |
| E-commerce | Catalogue and complete purchase process | Scoped separately, normally above €2,400 |
The final price depends on pages, languages, states, documents, third parties and processes. The first 12 months cover the agreed scope; new functions or content require a new evaluation.
Stated limitation
No solution offered is an automatic certification, a guarantee of legal compliance or legal advice. The panel and automated tests do not replace manual evaluation.
Verified official sources
Commercial articles are not enough for a legal topic. These are the primary sources used for this guide.
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Normattiva — Legislative Decree 27 May 2022, No. 82Open source · new tab
Italian legislation implementing Directive (EU) 2019/882, covering scope, definitions, requirements, exemptions and oversight.
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Normattiva — Law 9 January 2004, No. 4Open source · new tab
Italian law on access to information technology for people with disabilities.
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AgID — Service accessibility Guidelines, 2026Open source · new tab
Operational guidance adopted under Article 21 of Legislative Decree 82/2022.
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AgID — Accessibility and usabilityOpen source · new tab
Framework for public and private organisations, accessibility declarations and guidance on entities above €500 million.
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EUR-Lex — Directive (EU) 2019/882Open source · new tab
Official European Accessibility Act text on accessibility requirements for products and services.
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W3C — Web Content Accessibility Guidelines 2.2Open source · new tab
International technical Recommendation containing Level A, AA and AAA criteria and conformance requirements.
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W3C — WCAG-EM 1.0Open source · new tab
Methodology for setting scope and evaluating website conformance in a structured way.
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European Commission — European Accessibility ActOpen source · new tab
The EU institutional overview of the Act’s objectives and covered products and services, including e-commerce, banking, transport and e-books.
Sources accessed and verified on 22 July 2026. Before an audit or statement, always check the current legislation, applicable standards and authority guidance again.
Frequently asked questions about website accessibility
Direct answers to common questions about duties, exemptions, e-commerce, WCAG and widgets.
Must every website be accessible by law?
No. Italy does not impose one identical blanket duty on every private website. The organisation, service, audience, business size and applicable rules must be checked.
Is a brochure website subject to the European Accessibility Act?
Not automatically. A purely informational site may be outside the EAA scope, while a journey intended to conclude a consumer contract may count as e-commerce. The real process must be analysed.
Are microenterprises exempt?
Microenterprises providing services are exempt from the duties in Legislative Decree 82/2022. The definition requires fewer than 10 people and annual turnover or annual balance-sheet total no higher than €2 million. Other duties may still apply.
Is an accessibility widget mandatory?
No. The law does not prescribe one universal button or sidebar. The website or service must be accessible as a whole; a preference panel is only an additional aid.
Does a widget make a website WCAG conformant?
No. It cannot automatically fix every structural, keyboard, focus, form, content, document and complete-process issue. The real website must be evaluated and remediated.
What is the difference between WCAG 2.1 and WCAG 2.2?
WCAG 2.2 adds criteria to 2.1, especially for focus, dragging, target size, consistent help and accessible authentication. W3C recommends the latest version; the applicable regime may still require a specific mapping.
Can an automated test certify a website?
No. Automated tools identify only some defects. Alternative-text quality, focus order, usability, screen readers, contextual contrast and complete processes require human evaluation.
How much does making a website accessible cost?
It depends on pages, languages, components, documents and processes. Baseline accessibility is included in the websites I build; the documented WCAG package starts at €1,800 and increases with complexity.
Are accessibility and SEO the same thing?
No. They share some good practices, such as clear structure, readable text and understandable links, but have different goals and criteria. Accessibility does not guarantee ranking, and SEO does not guarantee accessibility.
Does a website remain conformant forever after remediation?
No. New content, components, languages, documents, third parties and checkout changes can introduce regressions. Responsibility, checks and periodic revalidation are required.
Next step
Need to know whether your website falls within scope?
Review the scope, included work, testing and maintenance of the WCAG package. Assessment starts from the real case and is not an automatic certification.