Have you heard about the new digital accessibility requirements arriving in Europe in 2025? If so, perhaps you are wondering if your company needs to be concerned about them.
By June 2025, a European directive requires many private companies to make their websites and digital products fully accessible. If your company has certain characteristics, these changes could affect you.
However, accessibility isn't just a matter of compliance: there are many good reasons to improve the accessibility of your websites and apps; there are opportunities to seize. Designing accessible products is a valuable opportunity to promote inclusion, expand your potential market, and optimize the user experience for everyone (not just people with disabilities).
At AND EMILI, we've been working on accessibility for a while now: we'll briefly explain what you need to know from a regulatory, ethical, and business perspective.
Contents:
- Accessibility: definition and standards
- What does the law say about accessibility?
- Compliance and risk of lawsuits
- Accessibility benefits everyone, in any case
- AI and accessibility
Accessibility: definition and standards
What do we mean by accessibility?
Accessibility is defined as the set of design, technical, and functional practices and measures aimed at making the web and digital applications readable and usable by all users, including all people with disabilities. Accessible websites must be designed to accommodate a wide range of conditions, including blindness, low vision, deafness, hearing loss, motor disabilities, cognitive disabilities (such as dyslexia), color blindness, and neurological conditions (such as epilepsy). The notion of disability can be extended to temporary conditions (such as the effects of surgery), whether legally certified or not.
The practices and technological requirements for digital accessibility have been codified through various international standards: one of the most widely adopted is the WCAG (Web Content Accessibility Guidelines) developed by the World Wide Web Consortium (W3C). Both European and Italian legislation explicitly refer to WCAG version 2.1 to define the compliance criteria for digital products.
What does the law say about accessibility?
Let's briefly look at the regulatory framework.
At the European level, EU Directive 2019/882, also known as the European Accessibility Act, required all Member States to adopt specific regulations on digital accessibility by June 2025. This directive significantly extends the accessibility obligation to economic operators who place products on the market or provide services, aiming to make products and services more accessible to people with disabilities.
In Italy, the European directive was already transposed in 2022, extending Law 4/2004 (the so-called "Stanca Law") which previously only concerned the websites and applications of the public administration. In compliance with the European standard, Italian law prescribes, from June 2025, the obligation to make websites and applications fully accessible for private companies that:
- have more than 10 employees,
- have an annual turnover exceeding 2 million euros,
- operate in specific sectors that provide goods and services for people.
What are the affected sectors and categories?
Regarding products, the European law refers to hardware and software systems, self-service terminals (such as ATMs), equipment for electronic communication and audiovisual media services, and e-readers. Among the services, the following are included: telecommunications, audiovisual media services (such as streaming platforms), certain aspects of passenger transport services (such as websites and electronic tickets), consumer banking services, and e-commerce.
Compliance and risk of lawsuits
Does your company fall into the categories affected by the legal obligations?
If so, since 2022, in Italy you are required to submit a declaration of accessibility (full or partial) for your websites to Agenzia per l’Italia Digitale (AGID) and to publish it by including the link in the website footer.
From June 2025, the requirement of full accessibility (or of having a plan to achieve it shortly) according to the WCAG 2.1 guidelines will come into effect.
Failure to comply with these regulations can lead to significant penalties in all EU Member States, which in Italy can amount to up to 5% of turnover. AGID is the Italian authority responsible for verifying the conformity of services with accessibility requirements: in case of non-compliance, it can order companies to adopt the necessary corrective measures.
It's important to remember that, to make sure that accessibility criteria are met, you should always talk to users, who should be included in the design and development phases to provide feedback. No automatic verification tool can replace testing with a real user: for example, a test with a blind user can highlight up to 80% of a website's accessibility issues.
Accessibility benefits everyone, in any case
Even if your company doesn't currently fall into the categories subject to legal accessibility obligations, investing in this area offers numerous significant advantages.
Let's look at some of them:
- Making your digital products and services accessible means reaching a wider audience, including not only people with disabilities, who represent a significant portion of the population, but also the elderly and anyone with temporary functional limitations: it's estimated that one in six people worldwide has some limitation in accessing digital services. This translates into a potential increase in users and therefore in business opportunities;
- a commitment to accessibility enhances your brand reputation, demonstrating your attention towards inclusion and social responsibility;
- an accessible website often benefits from better search engine indexing (SEO);
- accessibility optimizes the user experience for everyone, not just people with disabilities, improving the overall usability of the product;
- accessibility is an increasingly relevant aspect in ESG (Environment, Social, Governance) criteria for investments and capital raising.
Also keep in mind that addressing accessibility today can also prepare your company for future extensions of the regulations, avoiding more costly interventions later on.
AI and accessibility
Let's close our survey with a brief appendix on the hottest topic right now: artificial intelligence, which, being so ubiquitous, obviously has several implications in terms of accessibility as well.
When we talk about AI and accessibility, we can refer to:
- products based on AI models,
- code generation and control tools used by developers,
- the way users utilize AI tools to enhance their autonomy and independence.
Each of these topics is rapidly evolving and would require dedicated discussions. Here, we will limit ourselves to providing a few conversation starters.
Products based on AI models
If our company offers products based on artificial intelligence, such as a virtual agent based on LLM models, we must first ensure that it respects all the accessibility criteria prescribed by the WCAG, just like any other digital product. Then there are specific points of attention: the most well-known example is the research and mitigation of biases arising from the data on which the product is trained. That is, we must avoid as much as possible that our system reproduces distortions and prejudices against people with disabilities, or that it offers an "able-centric" perspective that is unbalanced in favor of non-disabled people.
Code generation and validation tools
In the field of software development, programmers have long benefited from AI tools that generate and validate code, such as GitHub Copilot. Some of these tools now offer assistance in generating accessible sites and apps, but they are not a "magic wand" for accessibility. The supervision of experienced developers and checking the software on the field with real users remain central to ensure that a product is fully and truly accessible.
How users utilize AI tools to be more autonomous
Finally, we must consider that, even if our sites and apps are not based on artificial intelligence, more and more users are utilizing it to consult them, effectively "adding" AI to our products even if we haven't directly implemented it.
Here are some significant examples:
- Visually impaired users have long learned to use their smartphones as "additional eyes": if they are unable to read or see a screen on a monitor (such as a "blue screen of death" on a PC), they will frame it with a visual recognition app capable of reading the content to them.
- Users with cognitive impairments can have the text of a web page summarized and reformulated to be more understandable for them and ask specific questions about what they haven't understood.
This last point leads us to a more general consideration that has to do with the way our sites, our apps, and our brand in general will increasingly reach users less directly and will be more and more mediated by "layers" of AI that will interpret our message for them.
This doesn't exempt us from thinking about accessibility by assuming that AI agents will take care of it: on the contrary, it requires constant monitoring to ensure that artificial intelligences "understand" our content and faithfully return it to users. Attention to copywriting, content structuring, the use of metadata, and the rendering performance of a site will continue to be fundamental in the world of AI, just as they are today for SEO, accessibility, and usability.
