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The accessibility statement: what it must say, and why declaring without measuring is worse than silence
In our study almost half of the sites publish one and exactly one passes the check. Here is who needs it, what it must contain and how to check your site before writing that it is fine.
| Sites with a statement | 43 of 89 |
| Sites with no errors | 1 of 89 |
| Who is exempt | under 10 staff and under €2M |
| Fines | €5,000 to €40,000 |
| Public reports | AgID platform since 11/03/2026 |
The number to start from
Of 89 analysable Italian e-commerce sites in our study, 43 publish an accessibility statement, 48.3%. Exactly one passes the automated check with no errors. The others declare themselves accessible, fully or partly, without the numbers confirming it.
A false statement is not a botched formality. It is a communication to consumers that does not match the truth, and in an inspection it becomes proof that the problem was known. An honest “partially compliant” with the list of what is missing beats a “compliant” written without measuring.
Who needs one
European directive 2019/882, implemented in Italy by legislative decree 82/2022, has applied since 28 June 2025 to services sold to consumers, e-commerce included. Those in scope must make available, in writing and in an accessible form, the information on how the service meets the requirements: in practice, the statement. Microenterprises are exempt, meaning under 10 staff and under 2 million in turnover or balance sheet: both conditions are needed. Fines run from 5,000 to 40,000 euro, plus 2,500 to 30,000 for failing to cooperate with the authority. The authority is AgID, and since 11 March 2026 it runs a public platform where anyone can report a site.
What it must contain
| Scope | which site or service it covers, with the address |
| Technical reference | EN 301 549 and WCAG 2.2 level AA |
| Status | compliant, partially compliant or not compliant: only one of the three |
| What is not accessible | the list of content that fails the requirements, with the reason |
| How it was assessed | by whom, when, with which tools and on which pages |
| Feedback channel | an address users write to when they hit a barrier, with response times |
| Enforcement route | the public AgID platform to turn to if the report goes unanswered |
| Date | when it was written and when it will be reviewed |
The content follows the model in the directive and in the AgID guidelines. The form may vary, the parts may not: if one is missing, the statement is incomplete.
How to check the site before writing that it is fine
Measure before you declare. Open the site in Chrome, press F12, pick the Lighthouse tab, tick only “Accessibility” and run it. In a minute you have a score and the list of errors found. Repeat on the home page, a product page, the cart and the checkout: those are the pages that matter.
Two things to know. Automated checks find roughly a third of the problems: a high score is not enough to write “compliant”, but a low score is enough to know you are not. And insufficient contrast is the leading cause on one site in two: it is also the cheapest to fix, usually a handful of colours in the stylesheet.
If you prefer, the form above runs the measurement on a sample of pages and sends you the result in writing.
Three mistakes we see often
- Copying another site’s statement. It lists their problems, not yours, and the date of their assessment.
- Writing “compliant” because the shop theme promises it. The theme is accessible until you customise it: banners, popups, brand colours and added apps are where it fails.
- No feedback channel. Without an address to write to, a user who hits a barrier goes straight to the AgID platform.
Prefer us to measure it
Automated check on a sample of pages against WCAG 2.2 AA rules, with the result in writing within 48 working hours. Free, and it starts only if you ask. If you then want the full inspection with the report and a draft statement, it is fixed-price and all in writing.
This guide is not legal advice. Thresholds and dates are those of legislative decree 82/2022 and AgID communications as of September 2026.