Website Accessibility: Is Your Property Exempt? (Yes, Probably — But Not Until 2030)

Two of the things you have been told about website accessibility are probably wrong. The first is that it concerns everyone and that you need urgent work done — usually said by whoever is selling the work. The second is that you have until 2030, which closed the conversation. The reality is simpler than the first and less reassuring than the second: many accommodation businesses are exempt, for a specific reason you can check in five minutes — and that “until 2030” does not mean what it appears to mean.

Here we explain how to work out which side you are on, exactly what Italy’s digital agency guidelines say, and why part of the work is worth doing anyway.

What we are talking about

The European Accessibility Act is directive 2019/882, transposed in Italy by legislative decree 82/2022. It does not only concern websites: it covers products and services, from cash machines to e-books. The obligations on digital services apply from 28 June 2025.

The supervisory authority for services is AgID, the Agency for Digital Italy, which in March 2026 published the guidelines implementing article 21 of the decree: the document setting out who is subject to the obligations, to what, and with which exceptions. That is where the two quotations that matter in this article come from.

First question: are you a micro-enterprise?

This is the question that decides everything, and two numbers answer it. The guidelines restate the definition in the decree:

“micro-enterprise”: an enterprise which employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding EUR 2 million

Original: «microimpresa»: un’impresa che occupa meno di 10 persone e realizza un fatturato annuo oppure un totale di bilancio annuo non superiore a 2 milioni di euro.

And, on who the obligations apply to, one sentence of seven words:

Micro-enterprises are exempt from compliance with the accessibility obligations.

Original: Le microimprese sono esentate dall’osservanza degli obblighi di accessibilità.

For most of the accommodation businesses we work with in Campania — B&Bs, rooms to let, holiday homes, small family-run hotels, tour agencies with two or three people — the answer is yes, and the exemption applies. Anyone who told you otherwise either has not read the guidelines or had something to sell you.

The three situations where the exemption does not cover you

It is not a blank cheque. Three cases to check:

1. You have grown. The test is applied to current figures, not to those from the day you opened. A property that went past ten staff two seasons ago is no longer exempt, and nobody sent it a notification.
2. The exemption applies to services. The regime for products is different: if besides selling stays you manufacture or distribute devices, that part has to be looked at on its own. Rare in tourism, but it happens.
3. The enterprise counts, not the sign over the door. If the property is part of a larger business, the test is applied to the enterprise, not to the individual building.

Second question: and if we are not a micro-enterprise?

Then the question becomes whether the service you offer online falls within the scope of the decree. The services covered are a closed list: electronic communications, access to audiovisual media services, passenger transport, consumer banking services, e-books and e-commerce services.

It is that last entry that concerns tourism, and the guidelines define it as services

provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract

Original: forniti a distanza, tramite siti web e servizi per dispositivi mobili, per via elettronica e su richiesta individuale di un consumatore al fine di concludere un contratto di consumo.

A booking engine on your website is exactly that: the guest, remotely, concludes a consumer contract. The same goes for the basket you sell tours through. A pure brochure site, which sells nothing online and points people to the phone or email, is in a different position — but it is also a site handing Booking the whole direct channel, which is a bigger problem than accessibility.

The “until 2030”: what it actually says

Here is the most widespread misunderstanding. The claim circulates as “existing websites have until 2030”. The guidelines say something else, in three parts:

until 28 June 2030 service providers may continue to provide their services using products (referred to in article 1 paragraph 2 of the decree) which they lawfully used before that date to provide similar services.

In addition, service contracts concluded before 28 June 2025 may be kept unchanged until they expire, but for no more than five years from that date.

Original: fino al 28 giugno 2030 i fornitori di servizi possono continuare a prestare i loro servizi utilizzando prodotti (di cui all’articolo 1 comma 2 del decreto) che utilizzavano in modo legittimo prima di tale data per fornire servizi analoghi. Inoltre, i contratti di servizi conclusi prima del 28 giugno 2025 possono essere mantenuti invariati fino alla loro scadenza, ma per non più di cinque anni da tale data.

Plus self-service terminals already in use, which may be used until the end of their economically useful life and in any case for no more than twenty years from when they were put into service.

“Disproportionate burden” and the funding trap

Those who are subject to the obligations have a partial way out: showing that compliance would impose a disproportionate burden, according to the criteria in annex V of the decree. It is not a verbal self-declaration — it has to be assessed, documented and communicated to AgID, which must be informed “immediately”.

And there is a clause that rules many out:

Service providers which receive public or private funding for the purpose of improving accessibility may not invoke the disproportionate burden.

Original: I fornitori di servizi che ricevono finanziamenti pubblici o privati, al fine di migliorare l’accessibilità, non possono invocare l’onere sproporzionato.

If you have taken grants intended for accessible digitalisation — regional calls, national recovery plan funds, tourism measures — that route is closed. It is worth rereading what the calls you won actually said before counting on this exception.

Who enforces it, and who is exposed to what

AgID assesses whether services comply and examines complaints: a consumer who considers a service unusable because of a disability can complain to the Agency. The procedures for verification, assessment and penalties are left to an AgID regulation, with a dedicated platform to handle the flow.

On the size of the penalties, the guidelines point to a very high bracket: the penalty of up to 5% of turnover applies to providers whose average turnover over the last three years exceeds five hundred million euro. That is not you, and telling you otherwise would be dishonest.

Which brings us to the real point of this article: if you are not obliged and you are not facing a penalty, why should you do anything?

Why it is worth it anyway, for different reasons

Not out of fear. For three commercial reasons.

The market. A significant share of European travellers have a disability or a functional limitation, and the percentage rises with age — and the average age of the European traveller with money to spend is rising too. A guest who cannot complete a booking on your site does not write to tell you: they go to Booking, where the form works.

The overlap. Almost every accessibility fix is a usability fix. Sufficient contrast, text that can be enlarged, buttons you can reach with a thumb, forms with clear labels, errors explained in words: these are the same things that raise conversion for everybody, with or without a disability. An accessible booking form is a booking form that works.

Machine readability. Semantic markup, alternative text, a consistent heading structure: this is the material screen readers work on, and it is the same material Google and the AI assistants work on. A site written properly under the bonnet is more accessible and more quotable. The same work, two results.

The eight things that fix most of the problems

On accommodation websites the recurring barriers are always the same. In order of effort against result:

1. Text contrast. Light grey on white is the most frequent aesthetic mistake and the easiest to correct: you change one colour in the stylesheet.
2. Alternative text on images that carry information. Not on decorative ones, where an empty alt is the right choice.
3. A booking form you can navigate by keyboard, with a sensible tab order and a visible focus. This is where bookings are lost.
4. Real labels on the fields, not just placeholder text that disappears when you start typing.
5. Error messages that say what to do, next to the field that is wrong, rather than a red border with no explanation.
6. Headings in order — one h1, then h2, then h3 — with no skips and without using headings as graphic design.
7. Nothing moving on its own without a way to stop it: automatic carousels and autoplay video are an obstacle for many and an irritation for everybody.
8. Touch targets big enough on phones, with space between one button and the next.

What not to buy

The accessibility market has its own repertoire of shortcuts. Two warnings.

Accessibility “overlays” — those widgets with the little figure icon that add a toolbar to the site — do not make a non-compliant site compliant. They act on top of the problem without touching it, they frequently conflict with the screen readers users already have, and they are the subject of documented criticism from disability organisations. They are not a solution: they are a paid sticking plaster, with an annual subscription.

Badges and certifications issued by whoever sells the service have no legal value. Compliance is a state of the website, verifiable by anyone on the site itself; a logo in the footer does not create it.

The questions we are asked most

We are a micro-enterprise: can we ignore all of this?

As far as the obligation goes, the exemption is explicit. Commercially, no: you lose the customers who cannot complete a booking either way, and half the items on the list above cost a few hours of work.

My site is on a standard CMS — is it already accessible?

No. A good CMS gives you the foundations — correct structure, fields for alternative text — but the barriers almost always arise in the theme, in the booking engine and in the content that gets uploaded. No platform makes a site accessible on its own.

The booking engine belongs to an external supplier: whose responsibility is it?

Towards the guest, yours: it is your site that does not work. Towards the supplier it is a matter of contract — and it is a legitimate question to put to them, asking for the answer in writing. If their form cannot be navigated by keyboard, it is a problem all their other clients have too.

Do I have to publish an accessibility statement?

The accessibility statement is an obligation attached to the earlier Italian legislation (law 4/2004), which for the digital service providers covered by the decree was disapplied on certain points from 28 June 2025, the statement included. If your particular situation calls for one, check it case by case: this is one of the points where a specific answer is better than a general rule.

What does it cost to put an accommodation website right?

It depends how it is built. On the items in the list — colours, labels, keyboard, headings, carousels — we are talking hours, not months, if the site is soundly built. If instead the theme produces disorderly markup or the booking engine is a closed box, the real cost is rebuilding those pieces, and it may as well go into the budget for the next rebuild.

In short

If you employ fewer than ten people and do not exceed two million, the AgID guidelines exempt you in a single sentence, and you can stop worrying about deadlines. If you are larger and you sell online, the date to remember is 28 June 2025 — past — and the “until 2030” you heard about concerns products already in use and contracts signed earlier, not your website.

Either way, the concrete work is the same and it is small: contrast, keyboard, forms, headings. You do it for the guests who would otherwise book somewhere else, not for an inspector.

The quotations in this article come from the guidelines on the accessibility of services implementing article 21 of legislative decree 82/2022, published by AgID; the guidelines exist in Italian only and the translations here are ours, with the original wording given alongside. This article is for information only and does not constitute legal advice: for your own situation, check the text of the decree on Normattiva and the guidelines on the AgID website, and consult a qualified professional.