Digital Accessibility in Spain

Spain has a well-established digital accessibility framework that has evolved significantly over the past two decades. Building on early national legislation from 2004 and 2007, Spain has progressively aligned its requirements with EU-wide standards, most recently through the transposition of the European Accessibility Act (EAA) into Spanish law via Ley 11/2023, which came into full effect in June 2025.

Today, accessibility obligations in Spain extend well beyond the public sector. Private organisations that provide products and services within the EAA's defined categories to consumers in Spain must now meet accessibility standards regardless of their size, provided they employ more than 10 people and have annual revenue exceeding €2 million. Organisations that fail to comply risk financial penalties, reputational damage, and exclusion from public sector procurement.

What is Ley 56/2007?

Ley 56/2007, de 28 de diciembre, de Medidas de Impulso de la Sociedad de la Información (the Law on Measures to Promote the Information Society) was one of the first pieces of Spanish legislation to impose digital accessibility obligations on the private sector. Enacted on 28 December 2007, it extended accessibility requirements beyond public sector bodies to specific categories of private organisations.

Under Ley 56/2007, the following private sector organisations were required to make their websites accessible:

• Companies providing financial services, including banks and insurance providers

• Companies providing passenger transport services

• Large retail businesses and e-commerce operators

• Public utilities including electricity, gas, and water providers

The law required these organisations to ensure their websites were accessible to people with disabilities and to provide accessible alternatives where full compliance was not immediately achievable. At the time of enactment, compliance with the UNE 139803 standard (Spain's national web accessibility standard based on WCAG 2.0) was the benchmark for demonstrating that obligations had been met.

While Ley 56/2007 was a landmark step in extending digital accessibility requirements to the private sector, it lacked specific enforcement mechanisms and technical precision. It laid important groundwork for subsequent legislation and established the principle that private sector digital accessibility is a legal obligation in Spain, not merely best practice.

What is Real Decreto 1112/2018?

Real Decreto 1112/2018, de 7 de septiembre, sobre accesibilidad de los sitios web y aplicaciones para dispositivos móviles del sector público is Spain's transposition of the EU Web Accessibility Directive (Directive 2016/2102). Enacted on 7 September 2018, it established clear and enforceable digital accessibility requirements for public sector bodies, replacing earlier guidance with a technically precise legal framework.

Real Decreto 1112/2018 applies to:

• Central government departments and ministries

• Regional governments (Comunidades Autónomas)

• Local authorities including city and municipal councils

• Public universities and educational institutions

• Healthcare bodies and the Spanish NHS (Sistema Nacional de Salud)

• Publicly funded organisations and bodies carrying out public service functions

• Private companies that receive any form of public funding and provide digital services to the public

The decree requires all covered organisations to:

• Comply with UNE-EN 301549, Spain's national adoption of EN 301 549, the harmonised European standard for ICT accessibility, which incorporates WCAG 2.1 Level AA in full

• Publish and maintain an accessibility statement (declaración de accesibilidad) for every covered website and mobile application

• Establish a functioning feedback and complaints mechanism enabling users to report accessibility issues and receive a response

• Create dedicated Accessibility Units responsible for overseeing accessibility reviews during development and conducting periodic checks after launch

• Submit triennial reports to the European Commission through the Ministry of Territorial Policy and Civil Service

Key compliance deadlines have already passed: existing public sector websites were required to comply by September 2020 and mobile applications by June 2021. All public sector bodies in Spain are therefore already subject to full enforcement under this decree.

What is Ley 11/2023?

Ley 11/2023, de 8 de mayo, de trasposición de Directivas de la Unión Europea is Spain's transposition of the European Accessibility Act (EAA, Directive 2019/882). It came into full effect on 28 June 2025 and represents the most significant expansion of Spanish accessibility law in the country's history, extending mandatory requirements to a broad range of private sector organisations for the first time under a comprehensive EU-aligned framework.

Ley 11/2023 applies to any organisation that provides products or services within the EAA's defined categories to consumers in Spain. Micro-enterprises with fewer than 10 employees and annual revenue below €2 million are exempt, but all other organisations operating in the following sectors must comply:

• E-commerce platforms and online marketplaces

• Banking and financial services providers

• Audiovisual media services

• Passenger transport operators including air, rail, bus, and maritime services

• Publishers of e-books and digital reading platforms

• Manufacturers and distributors of consumer electronic devices with digital interfaces, including smartphones, computers, tablets, and televisions

• Self-service terminals including ATMs, ticketing machines, and payment kiosks

The technical standard for compliance under Ley 11/2023 is EN 301 549 (UNE-EN 301549 in Spain), which incorporates WCAG 2.1 Level AA. Organisations must also publish accessibility statements and provide user feedback mechanisms, consistent with the requirements of Real Decreto 1112/2018 for the public sector.

Compliance timelines under Ley 11/2023:

• New products and services released after 28 June 2025 must be accessible from launch

• Existing products and services have until 28 June 2030 to meet full compliance requirements

• Self-service terminals already in use may have until 2040 depending on their installation date

Enforcement is overseen by the relevant sectoral authorities depending on the industry, alongside the general consumer protection framework under Real Decreto 193/2023, which regulates accessibility and non-discrimination in access to goods and services across all sectors.

Stylized web browser with a pop-up of a bulleted list; a magnifying glass over the accessibility symbol is in the right corner. Icons of gears are faded in the background.

What are the Requirements for Spanish Accessibility Laws?

Spanish accessibility law, across both the public sector framework of Real Decreto 1112/2018 and the private sector requirements of Ley 11/2023, requires conformance with UNE-EN 301549, Spain's national adoption of EN 301 549. This standard incorporates WCAG 2.1 Level AA in full for web and mobile content, and extends accessibility requirements to hardware, software, documents, and telecommunications infrastructure.

Key technical requirements include:

• Captions for video content: All pre-recorded video must include accurate captions to enable users who are Deaf or hard of hearing to access audio information. Live video must include real-time captioning where technically feasible.

Sufficient colour contrast: Text and images of text must maintain a colour contrast ratio of at least 4.5:1 against their background. Large text requires a minimum ratio of 3:1, ensuring readability for users with low vision or colour vision differences.

• Keyboard accessibility: All website and application functionality must be operable using a keyboard alone, without requiring a mouse or pointer device. Keyboard focus must be clearly visible at all times and must not become trapped within any component.

• Compatibility with assistive technologies: Websites, applications, and digital services must be compatible with screen readers, braille displays, voice control software, and other assistive tools. This requires correct use of semantic HTML, ARIA attributes, and programmatic labelling of all interface elements.

• Text alternatives for non-text content: All images, icons, and non-text elements must include descriptive alt text, ensuring users who cannot see them can access the same information via screen reader.

• Accessible documents: PDFs and other documents published as part of a digital service must be tagged and structured for assistive technology compatibility.

• Published accessibility statement: All covered organisations must publish and maintain a declaración de accesibilidad (accessibility statement) that states the conformance level of each service, lists known barriers and planned remediation timelines, and provides a contact method for users to report issues.

• Feedback and complaints mechanism: Organisations must provide a clear and accessible channel for users to report accessibility barriers and receive a substantive response within a reasonable timeframe.

For public sector bodies, the official accessibility statement template and submission process is managed through the Observatory of Public Sector Accessibility (Observatorio de Accesibilidad Web) operated by the Spanish government.These are just some of the success criteria included in WCAG 2.0. For a more detailed list, check out our WCAG 2.0 checklist.

Benefits of Complying with Spanish Accessibility Laws

Beyond legal obligation, there are clear practical reasons for organisations to invest in digital accessibility in Spain.

• Avoid financial penalties and enforcement action. Non-compliance with Real Decreto 1112/2018 can result in regulatory action for public sector bodies and exclusion from public procurement. Under Ley 11/2023 and Real Decreto 193/2023, private sector organisations face financial penalties for non-compliance with EAA requirements. Enforcement is active across multiple sectoral regulators, and non-compliant products can be required to be withdrawn from the Spanish market.

• Reach a significantly larger audience. Approximately 4.3 million people in Spain live with a disability, and the broader population benefiting from accessible design, including older adults and people with temporary impairments, is considerably larger. Accessible digital services open your products and services to this audience without additional marketing investment.

• Meet public sector procurement requirements. Real Decreto 1112/2018 requires that contracts for the construction and modification of public sector websites and mobile applications include explicit accessibility requirements. Private companies supplying digital services to Spanish public bodies must ensure their products meet UNE-EN 301549 standards. Non-compliant suppliers risk disqualification from significant contract opportunities across central, regional, and local government.

• Demonstrate commitment to inclusion. Spain has a long-established legal culture around disability rights, dating back to the 2003 LIONDAU framework and reinforced through successive legislation. Organisations that demonstrate genuine commitment to accessibility signal corporate responsibility to customers, employees, and partners in a market where these values are well understood.

• Build better digital products. Accessible design improves usability for everyone. The requirements for Spanish accessibility compliance, including clear navigation, descriptive labelling, keyboard operability, and structured content, produce better digital experiences across your entire user base, not just for users with disabilities.

Meeting Spanish Accessibility Requirements: Your Next Steps

Spain's digital accessibility framework is comprehensive, actively enforced, and now applies to a much broader range of organisations following the EAA transposition via Ley 11/2023. Whether you are a public sector body already subject to Real Decreto 1112/2018, a private company in a regulated sector under Ley 56/2007, or a business newly brought into scope by the EAA, the technical requirements point to the same standard: conformance with UNE-EN 301549 and WCAG 2.1 Level AA, with published accessibility statements and functioning user feedback mechanisms.

Practical steps organisations need to take include:

• Auditing all websites, mobile applications, and digital documents against UNE-EN 301549 and WCAG 2.1 Level AA criteria

• Fixing identified accessibility barriers, prioritising those with the greatest impact on users with disabilities

• Publishing a declaración de accesibilidad for each covered service, keeping it updated as accessibility work progresses

• Establishing an accessible feedback mechanism enabling users to report issues and receive a response

• Ensuring that contracts with third-party developers, content providers, and technology suppliers include explicit accessibility requirements

• Building ongoing accessibility monitoring into development and content workflows so compliance is maintained as digital products evolve

At AudioEye, we can help you meet Real Decreto 1112/2018, Ley 11/2023, WCAG, and EN 301 549 requirements with our Automated Accessibility Platform. Combining automation and expert human review, we help you detect and fix more accessibility issues than any other provider, and maintain compliance as your digital estate evolves.

To get started, use our Website Accessibility Scanner. The scanner looks for common accessibility issues on your current site, giving you a deeper understanding of how accessible your site is and where improvements are needed.