AGID's New Digital Accessibility Enforcement Regulation Explained 2026

On May 15, 2026, Italy’s Agency for Digital Italy (AGID) adopted, by Determination No. 84/2026, a new regulation governing how it investigates and sanctions digital accessibility violations. This is a fundamental step towards ensuring full respect for citizens’ digital rights — confirming that the platforms and applications of public administrations and private entities included in the scope of the law are fully accessible to all users, without any form of discrimination.

This isn't a new law. It's the updated operational regulation that gives practical effect to two laws already in force, consolidating into a single framework two earlier regulations (adopted by Determinations No. 357/2019 and No. 355/2022).

What This Changes in Practice

The regulation doesn’t introduce new technical requirements. WCAG 2.1 AA alignment under the Stanca Law and the EN 301 549 standard under D.Lgs. 82/2022 remain the applicable benchmarks.

What changes is the procedural certainty. There is now a documented, published pathway — from complaint to sanction — with clear timelines, defined roles within AGID, and formal obligations on organizations to respond. The grey area that allowed passive non-compliance to persist without consequence is significantly reduced.

For a fuller picture of how the European Accessibility Act is being applied across Italy and other EU markets, including how enforcement differs country by country, see our dedicated overview.

The Legal Background: Two Laws, One Enforcement Framework

The new regulation operates under two pieces of legislation that have been in force for some time:

Law No. 4/2004 — the Stanca Law is Italy’s primary digital accessibility law, in force since 2004. It requires public administrations and certain private entities to make their websites and mobile apps accessible. Responsibility for compliance rests with designated managers (dirigenti responsabili) within each organization.

Legislative Decree No. 82/2022 (EAA legal guidance) is Italy’s transposition of the European Accessibility Act (EAA, Directive 2019/882). It came into force in July 2022 and has applied in full since June 28, 2025. It extends accessibility requirements beyond public sector websites to a broad range of consumer-facing products and digital services in the private market.

Until now, AGID’s oversight powers under these two laws were governed by two separate regulations. The new regulation replaces both, creating a unified, step-by-step enforcement process from first complaint to final sanction.

Who Is Affected?

The regulation covers a wider range of organizations than many realize.

Under the Stanca Law (Law 4/2004):

• All public administrations — their websites and mobile applications

• Private companies with average annual revenue exceeding €500 million over the past three years

Under the Decree Accessibility (D.Lgs. 82/2022):

Any organization — regardless of size or revenue — that provides services in the following categories to consumers in Italy:

• E-commerce platforms

• Banking and financial services for consumers

• Electronic communications services

• Services providing access to audiovisual media

• Passenger transport digital services: websites, apps, electronic ticketing, real-time information systems

• E-books and related software

Note: Micro-enterprises (fewer than 10 employees and annual turnover below €2 million) are exempt from the services provisions of D.Lgs. 82/2022, but not from product obligations.

How Enforcement Works: A Collaborative Process That Can Escalate

The regulation establishes a two-phase process, deliberately designed to resolve issues through dialogue before resorting to sanctions.

Phase 1: Pre-Investigative Verification

The Digital Civil Defender (Difensore civico per il digitale) — AGID’s designated digital ombudsman — opens a case when any of the following occurs:

• A user files a formal complaint via the link in an organization’s accessibility statement

• AGID’s own monitoring detects non-conformities in a website or mobile app

• A third party reports an inadequate or absent response to an accessibility request

Once a case is open, the Digital Civil Defender may request documents, review evidence, and consult AGID’s technical teams. If issues are confirmed, a formal report is issued specifying what needs to be fixed and asking the organization to propose a remediation timeline. The AGID Oversight and Security Division then monitors whether those corrections are delivered.

Cases can be closed at this stage — and are, when organizations respond and remediate within the agreed timeframe. Archiving without sanction is explicitly provided for when violations are absent or when the organization complies promptly.

Phase 2: Sanctioning Procedure

If an organization fails to act within the agreed deadline, the case escalates to AGID’s Legal Affairs and Public Contracts Division. The sanctioning procedure is formally opened within 30 days. The organization receives a contestation notice and a diffida (formal warning) — a final opportunity to comply before a decision is made. The Director General issues the final decision, and all sanctioning outcomes are published on AGID’s institutional website.

What are the potential sanctions?

• For violations of the Stanca Law by private companies: an administrative fine of up to 5% of annual turnover

• For violations under D.Lgs. 82/2022: fines within the limits set by Article 24 of the Decree (EUR 5,000 to EUR 40,000 per violation), calibrated to severity and harm caused — with collaborative behavior taken into account in the organization’s favour. For larger entities, namely those which already fall within the scope of the Stanca Law, Article 24 instead applies the fine of up to 5% of turnover.

• For persistent non-compliance under the Decree: AGID may additionally order service suspension or withdrawal of non-conforming apps from stores

Frequently Asked Questions

Does this regulation create new accessibility requirements?

No. It governs how AGID enforces existing laws — Law 4/2004 and D.Lgs. 82/2022. The technical standards remain unchanged.

My company has less than €500M in revenue and isn’t a public body. Am I affected?

Potentially yes, if you provide services covered by D.Lgs. 82/2022 — e-commerce, financial services, audiovisual, transport, e-books or electronic communications — regardless of your revenue. The €500M threshold applies only to the private-sector provisions of Law 4/2004, not to the EAA transposition.

What triggers a case? Can AGID act without a user complaint?

Yes. Cases can be opened by user complaints, third-party reports, or AGID’s own monitoring programme. Your organization does not need to receive a complaint to be investigated.

How long does an organization have to fix issues?

There is no fixed number of days. The regulation specifies a timeframe that is “reasonable and proportionate to the nature of the non-conformity.” Organizations are asked to propose their own remediation schedule, which AGID then monitors.

What is the role of the accessibility statement?

Significant. User complaints must be submitted via a link in the accessibility statement published by the service provider. An incomplete, outdated, or missing accessibility statement is both a compliance gap in itself and removes the primary mechanism through which users can formally raise issues.

Can sanctions be avoided entirely?

Yes — if issues are resolved during Phase 1. The regulation explicitly provides for cases to be closed without sanction when the organization complies fully before escalation. The process is designed to prefer compliance over punishment.

Where can I read the full regulation?

The complete text is available on AGID’s website: Regolamento recante le modalità di accertamento e di esercizio del potere sanzionatorio (PDF) (Italian)

Building Compliance That Holds Up Over Time

For most organizations, the challenge with digital accessibility isn’t understanding the requirement — it’s maintaining compliance continuously as products evolve, teams change, and new regulations layer in.

Accessiway’s platform gives organizations a live view of their accessibility posture across all digital properties, with expert audits that feed directly into an issue-tracking dashboard (including Jira integration), and accessibility statement management that keeps your public declarations accurate and compliant.

The goal isn’t to pass one review. It’s to build a program that holds up when AGID — or your users — come looking.

→ Book a free consultation to understand where your digital services stand today.

Sources: AGID press release, May 29 2026 | Full regulation text (PDF) (in Italian)