01 — What the European Accessibility Act is
The European Accessibility Act (EAA) is EU directive 2019/882 imposing accessibility standards on digital products and services sold to European consumers.
In Italy it was transposed by Legislative Decree 82/2022 (and later amendments). It applies mandatorily from June 28, 2025. The rule covers websites, apps, e-books, self-service terminals, banking services, telecom, transport, and generally any digital service where a consumer can complete a transaction.
The technical reference standard is WCAG 2.1 level AA (Web Content Accessibility Guidelines), specifically the harmonised norm EN 301 549. It is not optional, and you don't reach it by installing a plugin.
02 — Who is obligated
General rule: if you sell to European end consumers (B2C) and the service is digital, you are obligated. Specific sectors in the decree:
- B2C e-commerce
Any site selling products or services to European end consumers: fashion, food, retail, digital products, B2C SaaS subscriptions.
- Banks and financial services
Home banking, payments, investments, loans. Anything handling money accessible via web/app.
- Telecom and ISPs
Mobile/fixed telephony services, internet, contracts managed online (subscription, billing, support).
- Passenger transport
Ticket sales, bookings, real-time info, public transport navigation apps.
- E-books and digital content
Publishers selling e-books, reading platforms, content subscriptions.
- On-demand audiovisual services
Video streaming, internet TV platforms, training videos sold online.
Microenterprise exemptions: Legislative Decree 82/2022 provides partial exemptions for microenterprises (fewer than 10 employees and annual turnover under 2 million euros) limited to certain services. The safe move is to verify with a specific advisor — the exemption is not automatic and doesn't cover all cases.
03 — Italian fines
Administrative fines for EAA violations in Italy reach 40,000€ per single violation, with possible service-removal orders.
AGID (Agency for Digital Italy) and consumer authorities can receive complaints and open proceedings. The fine is cumulative: every non-compliant service or product counts as a separate violation.
More than the fine, however, there is reputational risk. A public complaint for inaccessibility — especially for banks, telecom, visible-brand e-commerce — is reverse marketing. Consumer and disability associations actively monitor large brand sites and publish results.
And again: people with disabilities who can't complete a purchase on your site can file class actions. In the United States this type of lawsuit (under ADA, conceptually similar to the EAA) generated more than 11,000 lawsuits per year in 2023 alone. In Europe the curve is just starting.
04 — WCAG 2.1 AA as the technical standard
WCAG 2.1 AA is the international web accessibility standard maintained by W3C. It's split in three levels: A (blocking — bare minimum), AA (mandatory for EAA), AAA (optional, high editorial standard).
The 4 WCAG principles (POUR):
- Perceivable: all content must be perceivable through multiple senses (text + image + audio). Alt text, captions, contrast.
- Operable: all functions must be usable via keyboard, not just mouse or touch. Tab order, visible focus, consistent navigation.
- Understandable: content and interactions must be predictable. Errors explained, declared language, clear labels.
- Robust: code must be compatible with current and future assistive technologies. Semantic HTML, ARIA where needed, W3C validity.
05 — The 8 most common violations you will find on your site
- 01Forms without associated labels
Input fields with placeholder but no <label for=...>. The screen reader doesn't read what to enter. Level A blocking error.
- 02Colour contrast below threshold
Grey text on white background with contrast ratio below 4.5:1. WCAG AA requires minimum 4.5:1 for normal text. Level AA mandatory error.
- 03Images without alt text
Decorative <img> need empty alt, informative images need descriptive alt. A product gallery without alt is inaccessible.
- 04Broken keyboard navigation
Menus, modals, dropdowns reachable only with mouse. Inconsistent tab order, invisible focus, escape that doesn't close modals. Blocking for non-mouse users.
- 05Validation errors only via red colour
Wrong field signalled only by colour (red) without text or icon. Colour-blind and screen reader users see nothing. WCAG SC 1.4.1.
- 06Disordered heading hierarchy
Page jumping from H1 to H4 without H2/H3. Screen reader loses structural context. Hard to navigate and to index.
- 07Videos without subtitles
Video content published without captions/subtitles. Inaccessible to deaf, hearing-impaired, and to those watching without audio in public.
- 08"Accessibility widget" plugins
Plugins that add an "accessibility" icon with font/contrast toggles. Fix nothing substantial. Several EU courts consider it compliance-washing.
06 — Audit checklist (what to check today)
Three steps you can do today on your site, in order of ease.
- Lighthouse audit (5 minutes). Open your site in Chrome, press F12, Lighthouse tab, select "Accessibility", click "Generate report". A score below 90 is already a red flag. Lighthouse catches about 30% of automatic violations.
- axe DevTools scan (10 minutes). Install the axe DevTools Chrome extension, run a scan on the top 5-10 most-visited pages of your site. axe finds violations Lighthouse misses (ARIA, semantic, keyboard).
- Manual screen reader test (30 minutes). Download NVDA (free, nvaccess.org) or use VoiceOver on Mac (Cmd+F5). Navigate the site ONLY with keyboard + listening. Try to complete the most important flow (purchase, registration, contact). Where you fail, there is a concrete violation.
If these three steps make you realise the site is in trouble, it's time for a serious audit. No plugins, no compliance-washing: you need fixes in the code and a publishable accessibility statement. That, yes, is the work I do.