Digital technologies have the potential to serve as valuable tools for ensuring the rights of persons with disabilities, as they can help to reduce or eliminate barriers and limitations. However, access to these technologies—and, more generally, their use—may itself present specific obstacles for persons with disabilities. Such barriers can lead to exclusion or difficulties in accessing essential goods and services, thereby hindering full social and economic participation.

It is therefore worth recalling that, as of 28 June 2025, Directive (EU) 2019/882—known as the European Accessibility Act (EAA)—will come into effect. In Italy, the directive was transposed into law by Legislative Decree No. 82¹ of 27 May 2022, to ensure that digital products and services are accessible to all, including persons with disabilities, in an autonomous, equitable, and non-discriminatory manner.

This legislation forms part of the broader European strategy to promote greater inclusiveness within the internal market and to safeguard the rights of persons with disabilities, in line with the European Union Strategy for the Rights of Persons with Disabilities 2021–2030. The EAA introduces specific requirements to make digital products and services accessible to persons with disabilities, thereby addressing the persistent digital barriers previously mentioned.

The new regulatory framework applies to private economic operators—including those based outside the European Union but operating within its market—across a wide range of products and services. In particular, the European Accessibility Act covers manufacturers, importers, distributors, and authorised representatives involved in the marketing of hardware with operating systems, such as computers, smartphones, tablets), electronic communication devices (e.g., routers, modems, telephones), e-book readers, interactive self-service terminals (ATMs, ticket machines, check-in kiosks), gaming consoles, smart TVs, and other devices providing access to audiovisual services.

The legislation also concerns providers of digital services in numerous sectors, including e-commerce (websites and apps for purchasing, selling or booking), consumer banking and financial services, telecommunications (telephony, SMS, email, VoIP), passenger transport (online ticketing, travel information), e-books and digital reading software, and access to audiovisual content (streaming and on-demand TV).

The EAA establishes a wide range of compliance obligations, extending from design requirements to information and documentation duties concerning products and services. These must be designed and maintained in conformity with the technical requirements set out by European harmonised standards, or, in their absence, with internationally recognised technical specifications for digital accessibility. Among the main technical references are the UNI EN 301549 standard and the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG)².

The requirements are based on the fundamental principles of digital accessibility, encapsulated in the acronym POUR: Perceivable, Operable, Understandable, and Robust. These principles extend beyond interface design to include technical documentation, labelling, user instructions, and interoperability with assistive technologies such as screen readers, alternative keyboards, and voice output systems.

Failure to comply with these obligations may result in significant administrative penalties imposed by national authorities—in Italy, the Agenzia per l’Italia Digitale (AGID)—and may lead to requests for modification or market withdrawal of non-compliant products, or to the adoption of corrective measures. A consumer reporting mechanism is also foreseen.

As shown, access to digital products and services has become a matter of both European and national regulation, particularly from the perspective of inclusion. This represents one of the most recent examples of regulatory efforts addressing phenomena that are, in many respects, constantly evolving. Rules and obligations in this field often struggle to keep pace with the rapid technological advances that render them quickly outdated. Nevertheless, the principle of accessibility to digital tools must remain firmly grounded, despite the practical and operational challenges it entails, since these tools are now essential for ensuring full participation in the social and economic life of our communities. The European Accessibility Act (EAA), transposed in Italy through Legislative Decree No. 82 of 27 May 2022, represents an important step forward—albeit within a complex system—towards realising this principle.

¹ The European Accessibility Act will apply from 28 June 2025 to all new products and services, while products already placed on the market before that date may continue to be sold until 28 June 2030, even if they are not compliant. Services already provided before 28 June 2025 must be brought into conformity by 28 June 2030, unless substantial modifications are made, in which case immediate compliance will be required.

² Certain categories of web content and applications are excluded from the scope of the Directive—for example, interactive maps, historical archives, and third-party content not directly managed by the operator. Moreover, micro-enterprises (with fewer than ten employees and an annual turnover below two million euros) are exempt from the obligations only in relation to services, not products. An exemption may also be invoked where compliance would require a substantial modification of the product or service, or would impose a disproportionate burden, to be assessed according to the proportionality criteria established by the Directive. However, such exemption is not automatic and must be duly justified and properly documented.