On December 3, 2025, the Italian Communications Authority (“AGCOM”) adopted Resolution No. 291/25/CONS (“Resolution”), establishing measures for the development of action plans on the accessibility of audiovisual media services for people with visual and hearing disabilities.
The Resolution implements article 31 of Legislative Decree No. 208 of November 8, 2021, transposing Article 7 of the Directive 2010/13/EU (as amended by the Directive (EU) 2018/1808) on audiovisual media services, pursuant to which audiovisual media service providers (“AVMS providers”) are required to progressively make their content and services more accessible to people with visual and hearing disabilities.
The Resolution is the result of a co-regulation process initiated in May 2022, when AGCOM established a technical committee (tavolo tecnico) pursuant to Decision No. 151/22/CONS, involving key stakeholders, including associations representing persons with visual and hearing disabilities. The Committee established the minimum criteria for the development of action plans, reflected in the Resolution.
Notably, the above provisions significantly innovate the previous national framework (as the former largely relied on voluntary adherence to pursue accessibility) and establish a legal obligation for service providers, including private AVMS providers and the public service broadcaster (RAI), to make sure that their services are accessible to everyone.
Under the Resolution, AVMS providers are required to develop, on at least a triennial basis, action plans identifying the accessibility measures to be adopted in each calendar year starting from January 1st, 2026. The first action plans had to be communicated to AGCOM by December 31st, 2025. Providers shall periodically report to AGCOM on the implementation of such measures. The aim, in line with the principles of non-discrimination and inclusion enshrined at European and national level, is to gradually break down the barriers that limit the enjoyment of audio-visual content by users with sensory disabilities, ultimately ensuring equal opportunities for access to information and entertainment for everyone.
The Resolution applies to AVMS providers, both linear and non-linear, subject to Italian jurisdiction, including RAI. However, during the initial implementation phase, the measures do not apply to: (i) providers with advertising revenues below ten million euros in each of the last two financial years (calculated at group level where applicable); (ii) local audiovisual media service providers; (iii) pay audiovisual media service providers; (iv) radio broadcasters; and (v) radio media service providers offering audiovisual content (so-called “radiovisione”). Each provider shall establish incremental annual accessibility quotas for people with visual and hearing disabilities in its action plan, taking into account the principle of proportionality with reference to the size of the editorial group.
The Resolution identifies three accessibility techniques that providers must employ: (i) subtitling for deaf or hard-of-hearing persons; (ii) Italian Sign Language (LIS); and (iii) audio description for blind or visually impaired persons. AVMS providers must ensure a high level of quality in the techniques employed.
In selecting the techniques to be applied, AVMS providers shall respect the principle of non-discrimination between people with visual disabilities and people with hearing disabilities. Furthermore, in identifying the programming to be made accessible annually, AVMS providers shall prioritize: (i) information services (news programs and in-depth information programs), as services of general interest; (ii) programs aimed at minors; and (iii) content produced in the last five years, including self-produced content and European works, to ensure the timeliness of the accessible offering.
AGCOM has established a structured annual monitoring mechanism. AVMS providers shall submit detailed annual reports to AGCOM by February 15th of each year following the reference period (15 April for RAI). AGCOM shall publish an annual summary of the monitoring conducted on its website.
From an operational standpoint, AVMS providers falling within the scope of the Resolution shall take concrete steps to ensure compliance. Particular attention must be paid to the existing obligation requiring that all emergency communications to the public (including civil protection warnings, weather alerts, and public service announcements) be made accessible through subtitles and/or sign language interpretation to effectively reach all audiences, including those with sensory disabilities during critical or emergency situations.
From an organizational perspective, AVMS providers shall establish effective systems for collecting the data required for annual reporting to AGCOM. In case of non-compliance, AGCOM shall issue a warning, following a formal notice, requiring the provider to comply within a specified period of time. Failure to comply would trigger administrative sanctions ranging between EUR 30,000 and EUR 600.000. Specific obligations shall also apply to RAI.
The Resolution represents a significant step towards a more inclusive media ecosystem. AGCOM has published on its website (www.agcom.it) the reporting template that providers shall use for their annual reports. AGCOM has reserved the right, following verification of the first action plans, to adopt any further measures deemed appropriate to ensure the progressive accessibility of media services to people with visual and hearing disabilities, in accordance with the principles of non-discrimination and proportionality.
For more information, please see AGCOM’s Decision n°291/25/CONS, available here.
