Digital accessibility: design for people
Interview conducted before 28 June 2025; European Accessibility Act (EAA) rules have applied since 28/6/2025.
Accessibility has been mandatory for many digital services since 28 June 2025. But what does guaranteeing accessibility really mean? Is complying with the rules enough to offer an inclusive experience?
Since 28 June 2025, Italy’s Legislative Decree 82/2022 has applied, implementing the European Accessibility Act (EAA), Directive (EU) 2019/882, for the products and services within its scope. Becoming accessible, however, is not only a matter of following rules, or of ticking a checklist at the last minute. It has to do with the experience we offer people through our digital products and services. Organisations should therefore treat the new requirements as an opportunity both to rethink the user experience (UX) and to reorganise internal processes.
We discussed this topic with someone who works on design every day: Emmanuel Mazzucchi, head of user experience and user interface (UX/UI) design and accessibility expert at Conflux.
What the Accessibility Act is, in brief
The European Accessibility Act (Directive (EU) 2019/882) is a piece of legislation that sets a common set of accessibility requirements for digital products and services across the European Union. Its purpose is to protect the right of people with disabilities to take a full part in society, and also to remove the fragmentation of rules among member states.
In practical terms, the European Accessibility Act (EAA) makes digital accessibility a mandatory attribute for specific products and services placed on the market from 28 June 2025. It applies, for example, to e-commerce platforms, banking services, transport service websites and apps, e-books, smartphones and computers, and services that give access to audiovisual content.
The definition of digital accessibility
But in practice, what does it mean to be accessible? The directive asks that digital products and services be perceivable, operable, understandable and robust. These four principles are not new: they underpin a globally recognised standard, the Web Content Accessibility Guidelines (WCAG).
Even though the law does not say so in so many words, following the WCAG 2.2 standards (or later) at level AA is in practice the safest and most widely recognised way to meet the requirements of the EAA, and to make sure that a site or an app is genuinely compliant.
Beyond the checklist: why compliance alone is not enough
There is a fundamental difference between “being compliant” and “being genuinely accessible”. Compliance focuses on meeting technical requirements; accessibility, by contrast, is concerned with people’s actual experience.
If we limit ourselves to ticking items off a list, the risk is just around the corner: we create products that pass automated tests, but that in practice remain hard to use, frustrating, or simply exclude part of our audience.
Improving everyone’s experience through considered design
Designing for accessibility in a considered way is, by contrast, an investment in the overall quality of the experience. It means:
- making navigation and use of the product clearer and more intuitive for anyone;
- removing barriers, including less obvious ones such as information overload or complexity;
- communicating care, attention and respect, and building a relationship of trust with every user.
In the end, the real question is not whether your site complies with the law. It is whether it offers the best possible experience to all the people you want to reach.
Invisible accessibility
An accessible interface does not have to look different, more complex or “special”. On the contrary, the best accessibility is the kind that works without being seen. It is built into the design and makes the experience feel natural for everyone, including people who use a keyboard, a screen reader, or who have cognitive difficulties.
These can be small design choices that still have a huge impact: a button with the right label, an error message that helps someone fix the problem, a navigation flow that guides the person without confusing them.
Accessibility becomes a standard that helps teams design digital products and services with a good user experience.
A word from someone who designs every day: interview with Emmanuel Mazzucchi
To understand more clearly how to approach this change, we asked Emmanuel Mazzucchi, head of user experience and user interface design and accessibility expert at Conflux, to share his view.
We talked about what might happen after the legislation comes into force, and also about what we can (and should) start doing today. And about the essential role that project teams can play in making digital services genuinely inclusive.
Italian organisations facing the accessibility challenge
In your view, are Italian organisations ready to deal with the changes required by the updated legislation?
The picture of Italian organisations from an accessibility point of view is very mixed. There is a great deal of confusion, also because of the way these topics are communicated, both commercially and by institutions.
Many people confuse the obligations of the European Accessibility Act with those of the Stanca Law; many are convinced that these are the only two rules that concern accessibility.
The Accessibility Act was already transposed two years ago (Legislative Decree no. 82/2022), but the technical standards that help us put these rules into practice are running behind.
We hope that the new guidelines from the Agenzia per l’Italia Digitale (AGID), currently under consultation, can help in this respect; we are counting on a richer and deeper version than the first draft, published in mid-May.
The draft of the new version of UNI EN 301549, on the other hand, looks very promising to me, full of useful and concrete tools for representing the complexity of the various sectors touched by the EAA.
Organisations that did not start in time now see very close deadlines, and struggle to work out precisely what to do in a short period. On the other side, those who communicate with organisations — consultancy firms and institutions — could also do better, and help to make things clearer.
The role of legislation as a push for change
Do you think legislation on its own is enough to generate a real change in the design of digital services?
Everyone hopes for a cultural change. If the approach is “let’s do the bare minimum so we don’t get a fine”, there is a risk of favouring superficial interventions, which in the long run become hard to manage and to maintain.
That said, I think it is only fair to recognise that the pressure created by legislative innovation is decisive, and not only because of the threat of sanctions.
Making products and services genuinely accessible to everyone, in every condition, is a path that never feels “complete”: you can always improve further. And that can create a deadlock in organisations, a difficulty in planning.
Accessibility legislation also has the merit of defining clearly which levels of accessibility are required of all organisations, and how to check whether they have been reached. That helps to set objectives and to plan.
Making a digital product accessible: mistakes to avoid
In your view, what is the most common mistake when someone tries to make a product accessible?
Stopping at the surface. We are in a hurry, we are late, the deadline is approaching: so we limit ourselves to cosmetic interventions, which do not touch the process of producing products and services, or the skills of the people who produce them.
In essence, I treat the symptom but I do not act on the causes of the problem, which may therefore come back if I continue to design in the same way.
The most concrete illustration of this approach is an “accessibility overlay” installed on a website: I am aware that I have problems, but instead of trying to solve them in my systems, I prefer to add a software layer that promises to hide some of them from my users, automatically. We all know that these solutions do not fix any of the problems upstream, and on the other side they cannot guarantee compliance with the legislation.
Accessibility skills inside teams
Who should be responsible for accessibility in a digital team?
The right answer to this question is, of course: everyone should take care of it.
Skills related to accessibility should be spread across the various levels of the organisation. More or less everyone should have the experience of using screen readers, or assistive technologies that really help you take the point of view of the people who use the product. Designers, people who work on development, people who create content.
But in my view, as well as concerning everyone, it is also right that it should concern someone in particular. Especially in phases of crisis or transition, it is important that there is a person who coordinates the effort on accessibility. The risk otherwise is that it is tackled in a fragmented, unsystematic way.
There are issues that cannot be seriously addressed if people continue to think in silos: the design silo versus the front-end development silo versus the content production silo, all the way to the testing phase.
It is an organisational challenge for many organisations, but it is also a great opportunity, because we know that energy and opportunities are released when silos are overcome. At the same time, though, there must be clarity in the attribution of responsibility.
Advice for project teams
Which tools or processes would you recommend introducing in teams in order to start working in a more inclusive way?
The great opportunity I see is precisely that of rethinking processes. With a series of advantages that go beyond accessibility.
As I was saying, some silos that have formed in organisations need to be opened up. A challenge, but also a great opportunity.
Adopting a modular and systemic approach is essential in order to be efficient. A well organised and well documented design system is a fundamental asset for guaranteeing accessibility, but it also produces many other benefits.
Portable Document Format (PDF) files are typically produced inside an organisation by many different people, in a poorly coordinated way. Having to guarantee the accessibility of these documents can be an opportunity to redefine the production process, the templates and the guidelines.
And at the centre, of course, are skills. Everyone agrees: from now on, everything we produce must be accessible. If, however, we continue to design and develop without the right skills, there will be extra costs downstream to guarantee compliance with the legislation. Training the team, as is often the case, is the initiative that promises the greatest return on investment (ROI).
Perspectives on the future of accessibility in the Italian market
What do you hope will change, in concrete terms, in Italian digital products over the next 12 months? And what is still missing in the digital market for accessibility to become a true priority?
We all hope that accessibility will be perceived not as a problem to solve or a cost to bear, but as an opportunity. We know it and we keep saying it: very many people benefit from accessible design, and services that work well for them also help the business. But it is still very difficult for the return on investment of accessibility work to be perceived.
If you think about it, even the various artificial intelligence (AI) agents everyone is talking about at the moment will be able to navigate your site better if it has been built in an accessible way.
I hope the next 12 months will help to bring clarity: updated technical standards shared with everyone, more aware stakeholders, and consolidated, shared practices.
What we can already do now for accessibility
The provisions of the European Accessibility Act (EAA) have applied since 28 June 2025. But if there is one fundamental lesson that the European Accessibility Act offers us, it is this: accessibility is not a layer to add at the end of a project in order to comply with a rule. It is built from the first day, as an integral part of the strategy.
This change of perspective translates into a few key principles that make the difference between a “compliant” product and a genuinely inclusive one.
- Go beyond compliance. The goal is not to pass a test, but to ask ourselves whether we are really meeting the needs of all people. The real question is about impact, not about the rule.
- Design with vision, not with urgency. A reactive, last-minute approach leads to fragile solutions. Accessibility requires a long-term view.
- Work as a team. Accessibility is not the task of a single person. It is a shared responsibility among designers, developers, content strategists and stakeholders.
- Test with real people. Automated tools are useful, but they will never replace feedback from people who use our products with assistive technologies or with different abilities.
- Choose clarity. Simple language, direct instructions and readable text are accessibility tools that should not be underestimated.
In the end, the EAA is not the finishing line. It is the starting point for building better, more effective and more human digital products. An opportunity for organisations to adopt a new view of quality, creating value for every single user.
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