Key Points of Spanish Legislation on Digital Accessibility

In June 2025, a new accessibility law will come into force in Spain. For this reason, many companies have already been working to ensure that their products and services are accessible. This new law represents a milestone in terms of inclusivity within the development process of any digital product—but it is not the only law currently in place, nor the only one to come.

At Aktios, we want to provide clear legal context regarding web accessibility regulations in Spain, covering both public and private sector products and services, while also highlighting their origins and how similar frameworks are applied globally. All of this, explained in plain, accessible language.

European and Spanish Legislation for the Public Sector

Since 2007, Law 56/2007 has required accessibility for:

• Public universities

• International cooperation instruments

• Companies managing public services

• Companies receiving public funding for the design or maintenance of their websites or mobile apps

• Other private-sector entities…

  
  

Later, at the European level, Directive 2102/2016 established that all EU Member States must ensure accessibility in public sector websites and apps.

Spain transposed this directive into Royal Decree (RD) 1112/2018, which applies exclusively to public sector websites and apps.

Accessibility Level

The Royal Decree 1112/2018 requires that, since 2022, all public sector websites and apps must comply with UNE-EN 301 549, equivalent to WCAG 2.1, Level AA.

Accessibility Statement

Organizations must indicate non-accessible content, explain why, and provide accessible alternatives. They must also offer a contact method for complaints, inquiries, or suggestions.

Responsible Units

The decree regulates the creation of Accessibility Units, responsible for tasks such as overseeing accessibility reviews during development and periodic checks after release.

The Ministry of Territorial Policy and Civil Service must submit reports every three years to the European Commission. To support this, Accessibility Units must present three annual reports since 2020:

• Report on handling complaints and claims

• Monitoring report on accessibility compliance

• Report on promotion, awareness, and training efforts

Accessibility Certifications

Although not mandatory, organizations may obtain an accessibility certification, which must be issued by a certification body formally accredited by ENAC.

Who Must Comply with Law 1112/2018

• General State Administration

• Regional administrations

• Local administrations: city councils, provincial councils, etc.

• Public entities of an administrative nature

• Public sector associations

• Judicial Administration: courts, tribunals, etc.

The decree also extends obligations to:

• Private entities receiving public funding (for design or maintenance of websites and apps)

• Public services (education, healthcare, cultural, sports, and social services)

• Private educational institutions financed with public funds

Since 2022, all public sector websites and apps are legally required to be accessible.

Legislation for the Private Sector

Law 56/2007 also applied to certain private-sector organizations, such as:

• Companies in sectors of high economic importance.

• Social networks.

• Private universities.

• Audiovisual service providers.

This law was repealed by Law 11/2023, which we will cover below. However, it’s important to note that these organizations should have been accessible for years already.

In 2019, the European Accessibility Act (EAA) was adopted through Directive 882/2019, which requires accessibility for a wide range of private-sector products and services. All Member States must transpose this directive. Any company operating in the EU must comply with UNE-EN 301 549 (WCAG 2.1, Level AA).

In Spain, two key pieces of legislation apply: Law 11/2023 and Royal Decree 193/2023.

Before the transposition of the EAA Directive, Royal Decree 193/2023 was issued, applying to all websites and mobile applications whose content relates to goods and services made available to the public. It will enter into force in 2029.

Shortly thereafter, Law 11/2023 was enacted as the official transposition of the European Directive. It applies to a broad range of private sector products and services.

While the two regulations are largely complementary, they have different scopes that must be complied with according to the deadlines set out in each law.

Law 11/2023 for the Private Sector

Implementation Deadlines

• Applies in June 2025 to all new products and services released after this date.

• Applies in June 2030 to all existing products and services (i.e., those released before June 2025).

What Counts as “New” or “Existing”?

The law leaves room for interpretation. The most common expert consensus defines three scenarios:

1. New products: created from scratch.

2. Existing products with:

   • Minor updates: bug fixes or security patches are not considered new products.

   • Major updates: if an existing product undergoes a “significant” update, it may be treated as a “new” product and therefore subject to the EAA rules.

3. Continuous improvement products: each new version released after June 2025 must comply with the EAA, unless it only includes minor updates.

Who Must Comply

Products

• Electronic devices: computers, smartphones, tablets, smart TVs, e-readers, etc.

• Self-service terminals.

  
  

Services

• Communication services: telephony, internet, television.

• Transportation services: air, bus, train, and maritime.

• Financial services: banking, insurance.

• Commerce: online sales.

  
  

Obligations

Service providers must ensure that their design and delivery processes comply with the requirements set out in the law. They must also:

• Include information assessing how the service meets accessibility requirements, presented in an accessible format.

• Ensure ongoing procedures to maintain accessibility.

• Adopt corrective measures in case of non-compliance and notify national authorities.

• Provide adequate and continuous training for their staff to ensure they acquire the necessary knowledge on accessible products and services.

Repeals

This law repeals Law 58/2007, which required companies of major economic importance to be accessible.

Therefore, older websites from such companies will not be required to be accessible until the new laws take effect.

General Requirements

 

Products and services must provide information about their operation in a multisensory, perceptible, understandable, consistent, and legible way, across multiple formats.

Websites and apps must be perceivable, operable, understandable, and robust.

Additional Requirements

Additional requirements apply depending on the sector. For example:

• Transportation services must ensure the accessibility of self-service terminals and provide accessible digital guides.

• Banking services must ensure information is understandable without exceeding a B2 complexity level.

• E-commerce services must provide accessible methods for identification, e-signatures, and payment systems.

Supervisory Authorities

Regional governments will determine their supervisory authorities, tasked with:

• Verifying accessibility requirements.

• Reporting on the law’s application to the Technical Support Unit of the General State Administration.

• Applying the infringement and sanction system.

Sanctions

Non-compliance will be sanctioned under the infringement and penalty system set out in the relevant sector legislation.

If not specified, the sanctions of the General Law on the Rights of Persons with Disabilities apply:

• €30,000 for minor infringements.

• €90,000 for serious infringements, which may also include suspension of subsidies or, in the case of products, restriction or prohibition of commercialization.

Royal Decree 193/2023 for the Private Sector

This Decree was enacted before the transposition of the EAA. It regulates accessibility for websites and mobile applications in the private sector whose content relates to goods and services available to the public.

Goods and Services

The Decree applies to goods and services available to the public.

• Goods: items, articles, and products—especially merchandise—whose provision does not constitute a service, made available to the public through ordinary market activity. (This applies, for example, to any e-commerce site.)

• Services: offerings available to the public by individuals or legal entities, public or private, whether remunerated or not. This includes industrial, commercial, craft, professional, artistic, recreational, or similar activities.

Who Must Comply

• Electronic communications services for consumers.

• Consumer financial services: banking, credit, payments, investment services, private insurance, pension plans, and insurance intermediation.

• Water supply services for consumers.

• Retail gas supply.

• Electricity supply for end consumers.

• Travel agency services.

• Passenger transport services: by road, rail, sea, or air.

• Retail commerce activities.

Accessibility Level

The Decree requires that private sector websites and apps comply with UNE-EN 301 549, equivalent to WCAG 2.1 Level AA.

Deadlines

•  Applies in January 2029 to all new goods and services released after this date.

• Applies in January 2030 to all existing goods and services.

Accessibility Statement

Companies must publish on their websites the accessibility level of their goods, services, premises, facilities, and procedures, and indicate whether they have initiatives specifically aimed at people with disabilities.

Additional Requirements

Additional requirements apply depending on the sector. For example:

• Transportation: taxi booking platforms and intermediaries must provide an accessible web-based communication method and an accessible text-based telephone service.

• Consumer sector: providers must make commercial offers, contracts, invoices, and complaint mechanisms available in accessible formats.

Other areas are also covered, regulating accessibility of facilities, services, and customer support.

Law 11/2023 also regulate this cases.

Sanctions

• €30,000 for minor infringements.

• €90,000 for serious infringements, which may also include suspension of subsidies or, in the case of products, restriction or prohibition of commercialization.

These are the typical fines for lack of accessibility in websites. For instance, CERMI (Spanish Committee of Representatives of Persons with Disabilities) filed complaints against RTVE, Grupo Santander, Iberia, Alcampo, Vueling, Endesa, among others, for failing to meet accessibility requirements.

International Legislation

Digital accessibility is a human right recognized in the Universal Declaration of Human Rights.

Each country is responsible for enacting and regulating laws to enforce these rights. To ensure consistency across nations, international treaties serve as guidelines for national legislation.

Accessibility Laws in European Countries

• France: transposed the EAA through the RGAA decree, aligned with WCAG 2.2.

• Germany: enforces BITV and BGG laws, requiring compliance with WCAG 2.2 Level AA.

• Italy: transposed the EAA with Decree 82/2022, effective from June 2025.

• Belgium: will fully implement the EAA in June 2025.

Accessibility Laws Worldwide

• USA: follows Section 508, which mandates accessible websites, apps, and documents based on WCAG 2.0, but must comply with WCAG 2.1 by 2027.

• Mexico: adapts EN 301 549, equivalent to WCAG 2.0 Level AA.

• China: enforces GB/T 37668-2019, referencing WCAG 2.0 and 2.1.

• Canada: since May 31, 2024, has adopted EN 301 549 for the private sector.

Other Regulations

Some autonomous communities in Spain have additional decrees. For example, Decree 209/2023 of Catalonia sets accessibility codes, reinforcing web accessibility aligned with WCAG 2.1.

Conclusion

Accessibility legislation represents a significant step toward inclusion, but there is still progress to be made. Both companies and public institutions must adopt a mindset of continuous improvement, implementing practices like Shift Left A11y to ensure products and services are accessible from the start.

At Aktios, we want to remind everyone that behind every regulation are real people with fundamental rights. By improving their experience, we are building a more equitable future for all, regardless of whether or not they have a disability.