Ley 11/2023: Spain’s Digital Accessibility Law
Spain’s National High Court has already fined a major airline €90,000 for an inaccessible website — under older, less strict law. With Ley 11/2023 now in effect, penalties can reach €600,000. Here’s what your business needs to know.
What is Ley 11/2023?
Ley 11/2023 is Spain’s national transposition of the European Accessibility Act (EU Directive 2019/882). Enacted on May 8, 2023, it extends digital accessibility obligations to the private sector with enforcement beginning June 28, 2025.
The law is overseen by the Ministry of Economic Affairs and Digital Transformation. Unlike some EU member states that have separate technical regulations, Spain relies directly on EN 301 549 as the compliance standard.
- E-commerce and online shops
- Banking and financial services
- Telecommunications
- Transportation and travel booking
Key Facts
Law: Ley 11/2023
Enacted May 8, 2023
Effective: June 28, 2025
Already in force
Standard: EN 301 549 / WCAG 2.1 AA
Harmonized European standard
Fines: €30,000–€600,000
Tiered penalty system
Real Enforcement: Spain Is Already Acting
Before Ley 11/2023 even took effect, Spain’s courts demonstrated that accessibility requirements are taken seriously. A major Spanish airline was fined €90,000 by the National High Court for maintaining an inaccessible website.
Inspected and sanctioned after accessibility complaints
Fine of €90,000 imposed for non-compliance
Appeal rejected — court upheld the fine and additional sanctions
- Fined €90,000 under the previous accessibility framework
- Failed 26 of 38 required accessibility indicators
- Barred from receiving public funds for 6 months
- Court dismissed the “good faith” defense
This case was decided under pre-EAA law. Ley 11/2023 penalties are significantly higher — up to €600,000 for serious violations. As complaints mechanisms mature and advocacy organizations become more active, enforcement is expected to increase.
Spain’s Layered Legal Framework
Spain has multiple overlapping accessibility laws. Understanding which applies to your business is important for determining your obligations.
Royal Legislative Decree 1/2013
General Disability Rights
Broad civil rights act prohibiting discrimination against people with disabilities. Applies to both public and private sectors. Predates the EAA and establishes the general framework for accessibility in Spain.
Royal Decree 1112/2018
Web Accessibility Directive Transposition
Spain’s transposition of the EU Web Accessibility Directive. Focused on the public sector: government websites and apps. Requires conformance with EN 301 549 and publication of accessibility statements.
Ley 11/2023
European Accessibility Act Transposition
Extends accessibility obligations to the private sector. Much broader scope than the WAD. This is the law most businesses need to be concerned about. Covers digital products and services sold to consumers in Spain.
Regional Regulations
Spain’s Autonomous Communities can impose additional requirements. Notably, Catalonia’s Accessibility Code (Decree 209/2023, effective March 2024) adds requirements beyond the national law. Companies operating in Catalonia may face additional obligations across sectors including banking, education, and transportation.
Who Must Comply?
Ley 11/2023 covers a broad range of products and services sold to consumers in Spain.
International Businesses
If you sell products or services to Spanish consumers, you must comply — regardless of where your company is based. This includes US, UK, and other non-EU businesses serving Spanish customers.
Exemptions
- —Micro-enterprises — Fewer than 10 employees AND turnover ≤ €2 million (services only — product manufacturers must still comply)
- —Disproportionate burden — Requires documented evidence — not a blanket exemption
- —Fundamental alteration — Only if accessibility would change the product’s core function
- —Archived content — Unchanged content published before June 28, 2025
- —Third-party content — Content not funded, developed, or controlled by the business
Timeline & Deadlines
Key dates for Ley 11/2023 compliance. New products and services must comply from June 2025, with a transition period until 2030 for those already on the market.
June 28, 2025
New products and services
All new products and services must meet accessibility requirements from day one.
June 28, 2027
Emergency communications
Emergency communications (112) requirements apply in specific cases.
June 28, 2030
Existing products and services
Products and services already on the market before June 2025 must be updated or discontinued.
June 28, 2045
Self-service terminals
Terminals installed before 2025 can remain until end of service life (maximum 20 years).
If your website serves Spanish consumers, it should already be compliant. The June 2025 enforcement date has passed.
Penalties & Enforcement
Ley 11/2023 establishes a tiered penalty system with significantly higher fines than previous Spanish accessibility law.
Minor
Small-scale issues, first-time minor violations
Moderate
Significant barriers affecting multiple users
Serious
Systematic non-compliance, repeat violations
- Repeat offenders: potential ban from operating in Spain for up to 2 years
- Loss of eligibility for public funding and subsidies
- Reputational damage and negative press coverage
Enforcement Bodies
Technical Requirements
Spain relies on EN 301 549 as the harmonized standard for accessibility compliance. For websites, this means meeting WCAG 2.1 Level AA.
The Standard: EN 301 549
For websites, Chapter 9 of EN 301 549 is most relevant — it directly maps to WCAG 2.1 Level AA. Spain does not have its own separate technical regulation.
- All WCAG 2.1 Level A criteria
- All WCAG 2.1 Level AA criteria
- Additional requirements for documents (Chapter 10)
- Software requirements (Chapter 11)
- Support services requirements (Chapter 12)
Version Note
EN 301 549 v3.2.1 references WCAG 2.1, not 2.2. WCAG 2.1 AA is technically sufficient for legal compliance. inclly scans against WCAG 2.2 AA, which is backwards compatible — so you’re covered for both current and future requirements.
Accessibility Statement Requirement
Businesses must publish an accessibility statement (declaración de accesibilidad) that:
- Explains the current accessibility status of the product or service
- Provides a way for users to report accessibility issues
- Describes remediation plans for known barriers
- Is published in an accessible format on the website
How inclly Helps with Ley 11/2023 Compliance
What Automated Scanning Catches (~40% of Issues)
- Color contrast violations
- Missing alt text on images
- Form label issues
- Heading hierarchy problems
- Keyboard navigation barriers
- ARIA attribute errors
What Still Needs Manual Review (~60% of Issues)
- Logical reading order for screen readers
- Meaningful alt text quality (not just presence)
- Complex interaction patterns
- Cognitive accessibility considerations
inclly Features for Spanish Compliance
- Scan results mapped to both WCAG criteria and EN 301 549 clauses
- AI-generated remediation guidance with code examples
- Audit trail documentation for legal compliance
- Scheduled scans for ongoing monitoring
- PDF export for compliance documentation
No automated tool — including inclly — can guarantee full compliance. We catch approximately 40% of WCAG issues and clearly flag the remaining 60% that require manual review. Full compliance requires a combination of automated scanning and human testing.
Compliance Checklist (Quick Reference)
Action items for Ley 11/2023 compliance:
Determine applicability
Do you serve Spanish consumers? Are you above the micro-enterprise threshold?
Audit your digital assets
Run automated scans plus manual testing against EN 301 549 / WCAG 2.1 AA.
Prioritize critical issues
Focus on barriers with highest user impact and legal risk.
Remediate and document
Fix issues and keep records of what was done and when.
Publish an accessibility statement
Include current status, known issues, and a feedback mechanism.
Establish ongoing monitoring
Accessibility isn’t one-and-done — schedule regular rescans.
Train your team
Developers, designers, and content creators all need baseline knowledge.
Frequently Asked Questions
Is Ley 11/2023 the same as the European Accessibility Act?
Ley 11/2023 is Spain’s national implementation of the EAA. While the core requirements are the same, Spain has its own penalty structure (fines up to €600,000) and enforcement mechanisms through Autonomous Communities and consumer protection agencies.
Does Ley 11/2023 apply to my business if I’m not based in Spain?
Yes. Any business that sells products or services to Spanish consumers must comply, regardless of where the company is headquartered. This includes US, UK, and other non-EU businesses with Spanish customers.
What’s the difference between Ley 11/2023 and Royal Decree 1112/2018?
Royal Decree 1112/2018 covers public sector websites and apps (Spain’s WAD transposition). Ley 11/2023 extends accessibility requirements to the private sector under the EAA. Most businesses need to comply with Ley 11/2023.
Are micro-enterprises exempt from Ley 11/2023?
Micro-enterprises (fewer than 10 employees and ≤ €2 million turnover) are exempt from service-related requirements. However, if you manufacture physical products, you must still comply regardless of company size.
What standard should I follow for Ley 11/2023 compliance?
EN 301 549, which incorporates WCAG 2.1 Level AA for web content. Meeting WCAG 2.1 AA effectively satisfies the web accessibility requirements under Ley 11/2023.
Does Catalonia have additional requirements?
Yes. Catalonia’s Accessibility Code (Decree 209/2023) imposes additional requirements beyond the national law across sectors including banking, education, and transportation. If you operate in Catalonia, check regional requirements too.
Has anyone been fined in Spain for accessibility violations?
Yes. A major Spanish airline was fined €90,000 in 2020 (upheld in 2024) for having an inaccessible website. This was under pre-EAA law — Ley 11/2023 carries even higher penalties.
Continue Learning
Explore related guides to deepen your understanding of European accessibility compliance.
EAA Compliance Checklist
EN 301 549 Chapter 9 web requirements mapped to WCAG 2.2 criteria.
EN 301 549 Guide
Complete guide to the European accessibility standard.
EAA vs WCAG
How the European Accessibility Act relates to WCAG and what compliance means.
WCAG 2.2 AA Checklist
All 50 Level A and AA success criteria with testing indicators.
Ready to Check Your Ley 11/2023 Compliance?
inclly scans against all EN 301 549 Chapter 9 web requirements, with results mapped to both WCAG criteria and EN 301 549 clauses.