Accessibility laws · Italy

Italy: Stanca Act

Italy's headline accessibility penalty is 5% of turnover, and almost nobody reading this will ever face it. That sanction only reaches private companies with average turnover above €500 million. The number that matters to everyone else comes from the European Accessibility Act's Italian transposition, where breaching the accessibility requirements carries an administrative sanction of €5,000 to €40,000. Two laws, two very different bills.

Of turnover, max sanction: 5%
Private-sector threshold: €500M
WCAG via AgID rules: 2.1 AA
Stanca Act enacted: 2004

What the law is

The Stanca Act, formally Legge 4/2004, made accessibility a legal duty in Italy back in 2004. Conformance is measured against the guidelines of AgID, the Agency for Digital Italy, which carry WCAG 2.1 Level AA through the Italian version of EN 301 549. Article 3 of the Act reaches much further than the phrase public administration suggests. It covers public administrations, public economic entities, private concessionaires of public services, and regional municipalized companies. It also covers public assistance and rehabilitation bodies, transport and telecoms companies with majority public capital, IT service contractors, and bodies governed by public law. And it covers anyone who takes public contributions or facilitations to deliver services online. That last category is the widest hook in the statute. Take public money to build or run a service on the web and you are inside this law, whatever kind of organization you are.

A 2020 law reached large private companies too. The test is average turnover above €500 million over the last three years of activity. That reaches Italy's biggest e-commerce, banking, transport and media platforms, and it puts them under the same conformance and declaration duties as public bodies. The practical deadline for adapting those sites and apps was November 5, 2022, and from 2023 the declaration has had to be renewed every year. AgID published an interpretive circular in December 2022 on which private subjects are covered and how average turnover is calculated. The existence of that circular tells you the €500 million test was contested in practice.

Since June 28, 2025 a second regime has been running, and it is the one most businesses fall into. Italy transposed the European Accessibility Act as Decreto Legislativo 82/2022. It has been in force since July 16, 2022, with the substantive duties starting on the June 2025 date. It covers consumer products and services without asking whether you clear €500 million, and it comes with its own sanctions. The €500 million figure has not vanished, mind. It still decides who faces the Stanca Act's turnover sanction, so a very large provider can sit under both. AgID supervises services and websites. The Ministry for Economic Development supervises products. That is two supervisory authorities, not one. And in March 2026 AgID moved. It adopted operational guidelines by determination on March 4, published in the Gazette on March 24, and it has since put out a separate regulation covering how reports and complaints are handled. A public reporting platform is part of that picture. We could not pin the platform's opening to a particular day from official sources, so take the direction as established and the date as not.

This applies to you if…

You are an Italian public administration, or one of the many bodies article 3 pulls in alongside them. Concessionaires of public services, majority public capital transport and telecoms companies, IT service contractors, bodies governed by public law, and anyone receiving public contributions to deliver services online all count. If you took public money to build the site, read this page as if you were a government department.
Your company offers services to the Italian public through a website or an app, with average turnover over the last three years of activity above €500 million. That is the Stanca Act's private-sector threshold, and it is the only route to the 5% sanction.
You sell EAA-covered consumer services into Italy and you are bigger than a microenterprise. A microenterprise here is a business with fewer than 10 employees where either annual turnover or balance sheet total is no higher than €2 million. This layer has applied since June 28, 2025 regardless of how far you sit from the €500 million figure. One Italian twist. AgID's March 2026 guidelines say the microenterprise exemption does not apply where the business has received public or private funding, including PNRR recovery funds, for accessibility improvements. Take the money for the work and you cannot then claim you were too small to do it.

What it technically requires

You need WCAG 2.1 Level AA, which AgID's guidelines carry through the Italian version of EN 301 549. Not 2.2. AgID said why in March 2026. It is holding at WCAG 2.1 because the European harmonized standard has not been formally updated by the European Commission. AgID expects to move once the EU adopts the new edition of EN 301 549. That single sentence explains the version lag on every European law page we publish. So build to 2.1 now, and watch for the switch.
The edition Italy is waiting on has a number, and it is worth pinning it down. The version cited in the Official Journal of the European Union is EN 301 549 V3.2.1, published in March 2021 and applying to the presumption of conformity since February 12, 2022. Italy publishes it as UNI CEI EN 301549. A revision carrying the web clauses up to WCAG 2.2 is drafted and working through ETSI's process, and there is no published version number and no date for it, so anyone who quotes you one is guessing. The practical consequence is that Italy's technical bar is decided in Brussels rather than in Rome. AgID has already said it will follow, so the day the citation moves is the day your deadline changes.
You have to publish an accessibility declaration on AgID's model and renew it every year by September 23. You file it through the government's central form service, not by posting it on your own site. That makes it a filing obligation, not a publishing one. The link has to sit in your website footer, labelled Dichiarazione di accessibilità or Accessibilità. For a mobile app the URL goes in the store listing and on your website. You report one of three states, conformant, partially conformant, or not conformant. And you need a route for users who hit a barrier to tell you about it.
If you are a covered public body, you also have to publish your accessibility objectives every year by March 31, through the same central form. That is a separate duty from the declaration, with a separate date. One thing to check before you file anything. AgID's own guidance says private service operators covered by Decreto Legislativo 82/2022 are exempt from publishing an accessibility declaration. Read at face value, that means a mid-sized Italian online store covered by the European layer but under €500 million has no declaration duty at all. That reading sits awkwardly against everything else, so confirm your own position with AgID before you rely on either answer.
The operational guidelines AgID adopted on March 4, 2026 added three things worth knowing about. Accessibility verification attestations now need a digital signature with a time stamp, which turns your audit report into a signed legal instrument. There are structured control sheets for websites, digital documents and mobile applications. And where one service serves both business and consumer customers, the whole service has to comply rather than only the consumer-facing parts. That last rule has real architectural consequences if you run one platform for two audiences.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

This law expects a published accessibility statement, and regulators check for it first. Generate yours free →

How it is enforced

There are two sanction regimes. Take them in the order you are likely to meet them. Under Decreto Legislativo 82/2022, breaching the accessibility requirements carries an administrative sanction of €5,000 to €40,000. Obstructing the authority, meaning failing to comply with its measures or failing to cooperate, carries €2,500 to €30,000. Both bands are administrative, and the statute adds the words that matter around them, which is that they apply unless the conduct amounts to a criminal offence. Those are the numbers almost every business reading this page actually faces. The Stanca Act's 5% of turnover only applies to private entities over the €500 million threshold, and even then it is not a first response. AgID sets a deadline to eliminate the infringement first, and the sanction follows only where that deadline is missed.

A user who hits a barrier reports it through the link your accessibility declaration is required to carry. If nobody answers within 30 days, or the answer is inadequate, they escalate to the Difensore Civico per il Digitale, Italy's digital civil rights defender. Since 2026 there is also a public AgID platform where anyone can report an inaccessible digital service directly, sitting under a regulation that sets out how a report gets checked, corrected, or turned into a sanction procedure. Two routes, both free to the person using them, and one of them a single form.

Public sector managers carry this personally. Article 9 of the Stanca Act makes non-compliance relevant to the measurement and evaluation of an individual manager's performance. It also triggers managerial and disciplinary responsibility under the law on public employment, and it expressly leaves criminal and civil liability untouched. So for a public body this is not only an institutional problem. It lands on a named person's record.

And the limit on all of that. No source we read records AgID actually imposing an accessibility sanction, on a public body or on a private company. The framework is complete, the reporting platform is live, and the enforcement record is still empty as far as we can see. Read the numbers as what the law allows rather than as what has happened.

Key dates

2004Stanca Act in force for public administrations
2020Simplification Decree extends duties to €500M+ private companies
2022Private-sector statements and conformance obligations running
Jun 28, 2025EAA layer applies to consumer services

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.