Italy transposed the European Accessibility Act through Decreto Legislativo n. 82/2022, building on two decades of existing domestic accessibility law. L'EAA è entrata in vigore in Italia il 28 giugno 2025. The Stanca Law (Legge 9 gennaio 2004, n. 4) brought digital accessibility requirements to Italian public bodies from 2004, and was subsequently extended to private companies. Italy is one of the few EU member states entering EAA enforcement with substantial institutional experience rather than building enforcement capacity from scratch.
In May 2026, AgID adopted Determination No. 84/2026, a new regulation formalising how digital accessibility violations are investigated and sanctioned. The regulation creates a clear, documented pathway from complaint to formal sanction, consolidating earlier procedures into a single framework covering both Law 4/2004 and the EAA transposition. Cases can be opened by user complaints, third-party reports, or AgID’s own monitoring programme. An organisation does not need to receive a complaint to be investigated. At Accessibility Days 2026, AgID’s Director General stated explicitly: “this will be the year of enforcement.”
The enforcement authority is AgID, the Agenzia per l’Italia Digitale, the national digital agency operating under the Ministry for Technological Innovation. AgID has published detailed technical guidelines for EAA compliance, including specific test procedures mapped to EN 301 549. Italy’s enforcement approach is expected to be technically competent and methodical, informed by that two-decade baseline.
The cure period
Italy’s most distinctive enforcement feature is its cure period. When AgID formally notifies an organisation of EAA non-compliance, that organisation has time to remediate all identified issues. The cure period is proportionate to the nature of the non-conformity: organisations propose their own remediation schedule, which AgID monitors. If remediation is complete and verified within the agreed timeframe, no financial penalty is imposed.
This is the most generous cure period in the EU. Italy’s approach reflects its longer history of working with organisations through accessibility remediation rather than moving immediately to financial sanction.
The cure period applies from formal AgID notification, not from the EAA enforcement date. An organisation that has not yet received a formal notice is not in a cure period. The clock begins when AgID issues its formal finding of non-compliance, following investigation of a complaint or its own audit activity.
The practical implication is that organisations which respond quickly and completely to an AgID finding can avoid financial penalties entirely. This makes the quality of the remediation response, and the organisation’s ability to demonstrate genuine progress within the agreed timeframe, as important as the original compliance position.
Financial penalties
If non-compliance is not remediated within the cure period, AgID may impose financial penalties. Penalties are graduated by severity and are expressed as maximum amounts, since actual penalties depend on the severity of the violation, its duration, the size of the organisation, and whether the failure was intentional.
| Violation category | Maximum penalty |
|---|---|
| Minor violations | €30,000 – €90,000 |
| Serious violations | €90,001 – €300,000 |
| Very serious violations | €300,001 – €1,000,000 |
| Large companies (€500m+ annual turnover) | Up to 5% of annual global turnover under the Stanca Law framework — may exceed €1,000,000 |
No named penalty decisions under the EAA framework have been published in Italy as of June 2026. Italy has, however, issued penalties under the Stanca Law in the public sector context, which gives some indication of how AgID approaches graduated enforcement.
The fine ceiling is among the highest in the EU. Ireland’s maximum on indictment is €60,000. The Netherlands’ standard ceiling is €300,000. Italy’s very serious violation ceiling of €1,000,000, plus the 5% turnover exposure for large companies, places it alongside Spain at the upper end of EU EAA enforcement. The cure period is the most generous; the penalties are among the most significant.
How enforcement works in practice
Italy’s enforcement pathway follows a structured sequence. A user who encounters an accessibility barrier contacts the organisation directly. If the organisation does not respond or does not resolve the issue, the user submits a formal complaint to AgID through its official complaint form. The organisation must respond within 30 days and must update its dichiarazione di accessibilità (accessibility statement) to reflect the complaint and any remediation steps taken.
AgID investigates the complaint and, where it finds substantive non-compliance, issues a formal notification. That notification triggers the cure period. If remediation is complete and verifiable within the agreed timeframe, no further action is taken. If it is not, AgID may refer the matter to the Ministry of Disability in severe cases and impose financial penalties.
The accessibility statement plays a formal role in the Italian process. An organisation that maintains an accurate, current statement, identifying what is not yet accessible, documenting remediation progress, and providing a working complaint mechanism, is in a stronger position throughout this sequence than one that does not. The statement is both a legal requirement and an evidential document.
Which organisations are in scope
Italy applies the standard EAA scope: e-commerce, banking and financial services, electronic communications, audiovisual media services, transport, and e-books. Any organisation offering these services to Italian consumers, regardless of where the organisation is headquartered, is subject to Italian EAA enforcement.
The microenterprise exemption requires both conditions to be met: fewer than 10 employees and annual turnover or balance sheet below €2 million. Meeting one condition alone is not sufficient for exemption. The disproportionate burden exemption is also available, but requires documented assessment; it cannot be claimed without evidence.
What genuine compliance requires
Italy’s enforcement framework rewards organisations that treat the cure period as a genuine remediation opportunity. An organisation that responds to an AgID notification with a credible, complete remediation plan, and executes it within the agreed timeframe, avoids financial penalty entirely. An organisation that treats it as a delay mechanism does not.
Genuine compliance under the EAA has four requirements regardless of jurisdiction: technical conformance with EN 301 549 (WCAG 2.1 Level AA); a published accessibility statement that accurately reflects the current state of the product; active governance with a named owner, a testing process, and a mechanism for catching regressions; and documentary evidence of ongoing management.
Italy’s cure period does not change what compliance requires. It changes the consequences of non-compliance for organisations that respond well when notified. The underlying standard is the same.
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