The European Accessibility Act has been in force since June 28, 2025. Eleven months in, we can look at numbers instead of predictions and see how the Italian market actually moved.
Fines haven't landed yet
In early 2026 no Italian company has been definitively sanctioned. AgID and other national authorities started with an educational approach: notices, audits, formal warnings. Moving to fines takes time — investigation, defense, administrative appeal.
Are we safe? No. The first fine will make the news, and nobody wants to be the first one.
Who actually got audited
Sectors under the lens: e-commerce above €2M revenue, banks and fintech, transport services. SMEs below the EAA threshold are technically out, but many ran voluntary audits to keep enterprise clients.
The pattern we see in our projects: B2B customers ask for an updated conformance statement. Without it, no contract. The market self-regulates faster than the authorities.
The most common audit findings
- Form fields without labels: still problem #1. Placeholder used as label, errors not linked via
aria-describedby. - Color contrast: "modern" design systems with grey-on-grey. Under 4.5:1 without noticing.
- Removed focus indicator:
outline: nonewith no visible replacement. Catastrophic for keyboard users. - Custom components without ARIA role: dropdowns built from
<div>and click handlers. Invisible to screen readers. - Videos without captions: 30-second marketing videos uploaded to YouTube and embedded without a
captionstrack.
What changed in tooling
Axe, Lighthouse and WAVE aren't enough. In early 2026 AI-driven auditors entered the scene, replaying complex interactions — multi-step flows, modals, drag&drop — and flagging what a human tester would catch. Stark and Accessibility Insights are now standard in our sprints.
But no tool replaces real user testing. The EAA conformance statement is a legal document: it requires manual assessment, not just automated scans.
What we expect in the next six months
First Italian fine before end of 2026, likely against a large e-commerce or banking service. Rising demand for accessibility statements in B2B contracts. Italian design systems will mature: Designers Italia and MUI already updated their tokens. Smaller players will follow.
The operational message for those who haven't done a serious audit: don't wait for the authority's letter. Just wait for the customer who asks for a statement you don't have.