With the upcoming enforcement of the European Accessibility Act, the digital world faces a challenge that goes far beyond mere regulatory compliance. In a context where “accessibility” is often equated with “simplicity” or “speed,” there is a risk of promoting a reductive—and ultimately harmful—understanding. The implications are not only technical or legal but directly impact individuals and, for companies, their bottom line.
European Accessibility Act: What it really requires
The European Accessibility Act (Directive EU 2019/882), transposed into Italian law through Legislative Decree 82/2022, is a European regulation aimed at ensuring that digital products and services are accessible to people with disabilities. Its goal is to harmonize rules across EU member states and enhance participation in society and the single market—thanks in part to technology.
Starting from June 28, 2025, the regulation will be fully enforceable for a range of public-facing products and services, including:
- Websites and mobile applications of private companies (particularly in the commercial sector)
- Banking services
- E-commerce
- Self-service terminals (such as ATMs, ticket machines, and information kiosks)
- Transportation services (digital booking and check-in systems)
- E-book readers and related software
- Electronic communication services (such as messaging apps)
The Act doesn’t apply only to the public sector, but also to private companies—provided their products or services fall within the scope outlined above. The law requires that these tools be usable by everyone, regardless of visual, auditory, motor, or cognitive impairments.
In case of non-compliance, competent authorities may impose sanctions, including withdrawal of products from the market.
It is important to emphasize that European regulations do not replace existing national laws—they complement them. Therefore, accessibility is not a new obligation, but rather a reinforcement of responsibilities that already exist.
Beyond the legal surface
The growing focus on digital accessibility is not driven solely by the obligations introduced by the new European regulation. The European Accessibility Act is, in fact, just one part of a broader legal framework governing accessibility. In Italy, for example, laws such as Law 67/2006 and Legislative Decree 216/2003 have long been in force, allowing anyone who faces discrimination in accessing digital services—whether public or private—to take legal action. And this goes beyond mere compensation: courts can order the removal of digital barriers within a set deadline, imposing daily fines in case of non-compliance.
It is therefore misleading to believe that only those explicitly covered by the European Act need to be concerned about accessibility. Every organization, regardless of its legal status or turnover, should assess the accessibility level of its digital channels—not only as a legal duty, but also as a matter of social responsibility and long-term sustainability.
Accessibility as an off-the-shelf product? Better not.
Alongside the rising regulatory attention, there has been a surge in commercial offerings that promise quick fixes for compliance. In many cases, these promises turn out to be illusions: automated tools that provide superficial “analyses,” 48-hour “express audits,” or even miracle plugins that claim to “fix” accessibility issues without making any real changes to the source code.
The reality is far more complex. No automated software alone can detect all accessibility issues. The Web Content Accessibility Guidelines (WCAG) are clear on this point: many evaluations require human interpretation, contextual understanding, and real-world user testing. Automated tools can only cover about 30% of the required criteria—the rest demands expertise, focus, and time.
Relying on “per-page” assessments misses the point: accessibility is not a checklist of minor errors—it’s a balance between usability, navigability, and clarity. A keyboard-inaccessible menu can completely block access to a website—far more critical than dozens of images lacking alternative text.
Percentages and promises: Misleading metrics
Using percentages to describe the accessibility level of a website is often misleading. Statements like “the site is 82.5% accessible” are essentially meaningless unless accompanied by a qualitative assessment of the issues identified. Moreover, relying solely on automated metrics means evaluating only a small fraction of the actual requirements—and, most importantly, failing to distinguish between critical and minor issues.
For example, an error in the description of a decorative image does not have the same impact as an error that prevents a blind user from completing an online purchase. Yet both may be recorded simply as “errors,” with no context or weighting applied.
Not just the public-facing side: Accessibility is internal, too
One of the most persistent—and incorrect—assumptions is that accessibility concerns only public-facing products. In reality, current regulations also apply to internal tools and documents. An inaccessible enterprise software system can significantly hinder the independence of an employee with a disability, exposing the organization to both legal liability and reputational risk.
The same applies to digital documents. The European technical standard EN 301 549 explicitly includes them among the elements that must be accessible. This doesn’t refer only to PDFs published online, but also to internal documents, whether generated by company software or created manually. And once again, while automated tools can provide an initial layer of support, true validation requires skilled human oversight.
The false sense of security in “partial compliance”
A now widespread practice is to declare “partial compliance” with accessibility standards—as if it were an achievement. In reality, European regulations regard partial compliance as a starting point, not a satisfactory end state.
Publicly acknowledging non-compliance with dozens of WCAG criteria does not mean being “legally covered.” On the contrary, it implies a clear responsibility: the obligation to implement corrective measures within a reasonable timeframe. Failing to do so leaves organizations exposed—both technically and legally.
“Magical” solutions? Best to be skeptical
Among the most misleading offerings are accessibility overlays—tools that claim to make a website accessible without altering its source code. In practice, these are often invasive technologies that interfere with screen readers, override native styles, and fail to improve the actual user experience.
In the United States, several companies promoting such products have already faced legal action for deceptive advertising. In Europe, there is a real risk of importing the same flawed model, fostering the illusion that accessibility can be outsourced to a plug-in.
The truth is, the only sustainable approach is one that integrates accessibility into the development process from the very beginning—not as a patch, but as a principle.
Conclusion: Accessibility is a process, not a product
The race toward fast, cheap, and superficial compliance is undermining the true meaning of digital accessibility. Easy fixes neither ensure legal compliance nor, more importantly, deliver real accessibility for people with disabilities.
Embedding accessibility into the design, development, and management of digital services is not optional—it is essential. Just like cybersecurity or data privacy, it requires a shared culture, a long-term strategy, and targeted investment.
Because in the end, ensuring accessibility is not just a legal obligation—it is a tangible act of inclusion. A commitment to equity, usability, and respect for all users, regardless of their abilities.
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