Understanding EAA Compliance: What Italian Businesses Need to Know

The European Accessibility Act in Italy matters for any company that sells or supplies certain products and services to Italian customers. This guide explains what the Act requires, how it sits alongside Italy’s existing accessibility laws, and concrete steps businesses can take to reach compliance before enforcement starts.

What the European Accessibility Act requires

The European Accessibility Act is an EU legal instrument that sets common accessibility requirements for specific products and services across member states. It aims to remove barriers for people with disabilities by requiring accessible design, documentation, support services, and information. Member states had to transpose the Act into national law by 28 June 2022, and the Act applies from 28 June 2025.

What the European Accessibility Act in Italy means for businesses

In Italy the Act complements existing obligations that already affect public bodies and some private actors. Companies that place covered products or provide covered services in Italy will need to demonstrate accessibility. That can mean design changes, new testing, and updated customer support. Preparation even for small changes can reduce the risk of enforcement actions and improve market access.

How the EAA differs from the Web Accessibility Directive and Italian rules

The Web Accessibility Directive primarily covers public sector websites and mobile apps. The European Accessibility Act covers a defined list of goods and services across both public and private markets. Italy also has national accessibility rules covering public administration websites and digital services. Businesses should treat the EAA as an additional obligation that applies to private products and services listed under the Act.

Products and services commonly covered

Not every product or service is in scope. Examples of items often included under the Act are:

• self-service terminals and ATMs
• computers, operating systems and smartphones
• consumer terminals and peripherals
• e-readers and e-book services
• ticketing and check-in machines
• online marketplaces and e-commerce checkout flows
• banking services, including online banking interfaces

Check whether a specific product or service you offer is listed by consulting national implementing measures or guidance from a competent Italian authority.

Standards and technical references to use

The Act points businesses to harmonised European standards that give a presumption of conformity if followed. In practice this means using technical references such as EN 301 549 for ICT accessibility and the Web Content Accessibility Guidelines. Organisations should follow the harmonised standards cited in national transposition texts or check whether later versions have been recognised by the EU.

Step-by-step compliance plan for Italian businesses

This plan is practical and aimed at small and medium businesses. Adjust the timeline and resourcing to match your size and risk.

Month 0: Scope and risk assessment

• Identify which products and services you place on the Italian market.
• Match each to the Act’s scope. If unsure, treat borderline items as in scope until clarified.
• Assign a lead: product owner, legal counsel or compliance officer.

Months 1 to 3: Audit and minimum fixes

• Run an accessibility audit covering digital interfaces, hardware UI and user documentation.
• Use automated tools for baseline issues plus manual checks for keyboard access and screen reader compatibility.
• Fix high-impact failures first: keyboard focus order, missing labels, colour contrast, and broken form controls.

Months 4 to 6: Design changes and verification

• Implement design and code updates. Use the harmonised standards as the technical basis.
• Perform assistive-technology testing with tools such as NVDA or VoiceOver and with real users with disabilities.
• Document test results and corrective actions in versioned records.

Months 7 to 9: Documentation, supplier controls and launch

• Create accessibility information for users, including how to get support and report problems.
• Update supplier contracts to require accessibility for components or embedded systems you buy.
• Prepare internal processes for continuous monitoring and periodic re-testing.

Ongoing: Monitoring and updates

• Include accessibility checks in product roadmaps and release cycles.
• Keep a remediation log and evidence package in case authorities request proof of compliance.

Quick technical checklist (digital and hardware)

• Ensure full keyboard operation and visible focus states.
• Provide meaningful labels for form fields and controls.
• Use semantic HTML and correct heading order in web interfaces.
• Provide text alternatives for images and non-text content.
• Meet colour contrast ratios for text and interactive elements.
• Offer accessible user guides and responsive customer support channels.

Testing: what to combine for reliable results

Do not rely on automated testing alone. Combine automated checks, manual inspections by trained testers, and user testing with people who use assistive technologies. Keep records that show who tested, what was tested, tools used, and results. That evidence is useful for procurement reviews and regulatory checks.

Procurement, contracts and supplier management

Include clear accessibility requirements in procurement documents and purchase orders. Ask major suppliers for conformity evidence against harmonised standards. Require maintenance and upgrades to continue meeting accessibility requirements after delivery.

Enforcement and business risks

National authorities in each member state enforce the Act. Enforcement can include orders to remediate products or services and measures that affect market access. Preparing early reduces business risk and can avoid disruption to sales in Italy and other EU markets.

Common mistakes to avoid

• Relying only on automated scans. Automated tools miss many real-world barriers.
• Treating accessibility as a one-off project. It must be part of ongoing product maintenance.
• Assuming public sector compliance equals private sector compliance. The Act expands scope to many private offerings.
• Failing to document testing and fixes. Records help demonstrate due diligence.

Practical checklist for small businesses

• Do a scope check and assign an owner.
• Run a combined automated and manual audit.
• Fix the top 10 critical accessibility issues first.
• Test with at least two assistive technologies and one person with lived experience.
• Publish simple access information and a support contact.
• Update supplier contracts to include accessibility clauses.

Where to get help

Look for accessibility consultants, test labs, user panels of people with disabilities, and sector trade associations. Also consult the Italian authority responsible for product safety and market surveillance for guidance on national implementation and recognised standards.

Taking steady, documented steps now will make it easier to comply with the European Accessibility Act in Italy and to keep your products and services usable for more customers.