EAA enforcement in Italy: AgID and the D.Lgs. 82/2022 fines

Which law applies

Legislative Decree 82/2022 transposes the Directive. Its substantive rules apply from 28 June 2025, and e-commerce is a covered service. Article 3(3) states that microenterprises providing services are exempt from the service accessibility requirements.

Separately, Law 4/2004 (the Legge Stanca) and AgID's guidelines for private entities already required large private companies, those with average turnover above EUR 500 million, to meet accessibility rules and publish a yearly accessibility declaration on AgID's model.

The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025.

The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added.

Who enforces it for online shops

AgID (Agenzia per l'Italia Digitale) supervises the digital services covered by the decree, including e-commerce; the Ministry of Enterprises and Made in Italy covers products (AgID). In 2026 AgID adopted a new regulation on how it supervises and sanctions, with a collaborative first phase before any formal sanction procedure, according to AccessiWay. We have not read the regulation text itself.

How a complaint reaches a shop

Users first report problems through the feedback mechanism in the service's accessibility statement. If that fails, the complaint can go to AgID, which can open a pre-investigation and then a sanction procedure (AccessiWay). We could not confirm a single central AgID complaint form as of 1 October 2026.

Fines and other sanctions

Article 24 of D.Lgs. 82/2022 sets:

• EUR 5,000 to EUR 40,000 for breaching the core accessibility duties, graded by the extent of the non-conformity, the number of services and the number of users affected;
• EUR 2,500 to EUR 30,000 for failing to comply with an authority order or failing to cooperate.

For large companies covered by the Legge Stanca, a separate sanction of up to 5% of turnover is widely reported. We have not confirmed that figure against the statute, so treat it as reported.

What has actually happened so far

We found no AgID fine or lawsuit against a named Italian online shop under D.Lgs. 82/2022 as of 1 October 2026. Italian commentary describes the country as behind on digital accessibility overall (Agenda Digitale), and AgID's 2026 regulation suggests the enforcement machinery is only now being built out.

What to do if you sell into Italy

If you sell to consumers in Italy and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.

1. Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
2. Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
3. Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
4. Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
5. Re-test after every redesign, theme update or new app, and keep the reports.

A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.