Accessibility laws · Spain

Spain: Royal Decree 1112/2018 and the EAA

Spain runs two accessibility regimes, and the newer one probably does not reach you. That is worth checking before anything else. The European Accessibility Act exempts a service provider with fewer than 10 people whose annual turnover or balance sheet total is no more than €2 million. That exemption is outright and complete. Royal Decree 1112/2018 is the other regime, and it is the demanding one. It is aimed at the public sector, at anyone running a public service under contract, and at any website that took public money for its design or its upkeep.

WCAG version named: 2.1 AA
Public sector decree: 2018
EAA application date: Jun 2025
Technical standard: EN 301549

What the law is

Royal Decree 1112/2018 brought the EU's Web Accessibility Directive into Spanish law, and Spain's own history explains why the timeline reads oddly. Public administrations already owed an accessibility duty here, under Real Decreto 1494/2007 and an earlier information society law. So Spain did not need the directive's phase-in for the duty itself. The decree came into force on September 20, 2018, and the duty came with it. What Spain staged instead was the complaints and claims machinery, over the following one and two years, plus the mobile app rules from June 23, 2021. So a Spanish public body's existing website was never given until 2020 to become accessible. It already had to be.

Article 5 states the requirement in plain functional terms, that content be perceivable, operable, understandable and robust. Article 6 then says you are presumed to have met it if you conform to the harmonized standards whose references are published in the Official Journal of the European Union. Where no such reference has been published, EN 301 549 is named as the fallback. In Spanish that standard is published as UNE-EN 301549, and the current edition carries WCAG 2.1 Level AA. The wiring underneath is easy to miss. Article 6.4 makes reference updates apply directly, so Spain's technical bar moves whenever the Official Journal citation moves, without anybody amending the decree. The standard is a moving target by design.

Spain transposed the European Accessibility Act as Ley 11/2023, and the EAA material sits in the first 31 articles, with surveillance, enforcement and sanctions in chapter XI. Those obligations have applied since June 28, 2025, the same date as everywhere else in the union. The private-sector reach is e-commerce, banking, transport, e-books, and consumer devices such as payment terminals and e-readers. Spain then added categories the directive never listed. This is where a European checklist will mislead you. Utility websites and mobile services, travel agency and tour operator sites, social networks, and a further terminal category are all named in the Spanish law. Two dates ahead of you get left out of most Spanish coverage, and one of them is misreported almost everywhere. June 28, 2027 is the latest a member state can start applying article 4(8). Article 4(8) is about answering 112, the emergency number, rather than about buildings. The built environment is a separate option in article 4(4), and no directive date attaches to it at all. The date that does reach you is June 28, 2030, which ends the transitional period. Until then a service provider can keep using products it lawfully used before June 2025. Service contracts agreed before June 28, 2025 can run on unchanged until they expire, but no longer than five years from that date.

This applies to you if…

You are a Spanish public sector body. Article 2 covers the General State Administration, the administrations of the autonomous communities, local administration, the institutional public sector, associations formed by those bodies, and the Administration of Justice.
Your website received public funding for its design or its maintenance. There is no threshold in the decree. The word substantial appears nowhere in it. Public administrations have to require the same accessibility criteria of three further groups. Sites that received public funding for their design or maintenance are the first. Sites of entities and companies running public services under concession or another contract are the second, with education, health, culture, sport and social services named specifically. Private educational, training and university centers supported wholly or partly with public funds are the third. Spain's publicly funded private schools sit squarely inside that last one.
You sell EAA-covered products or services to consumers in Spain, whether or not your company is based there. The act follows what reaches a Spanish consumer, not where you are incorporated.
You might be exempt outright as a microenterprise, and this is the fact most Spanish coverage leaves out. A microenterprise employs fewer than 10 people. On the money side it needs either annual turnover of no more than €2 million or an annual balance sheet total of no more than €2 million. Either figure satisfies that half on its own. Article 4(5) of the directive then exempts a microenterprise providing services from the accessibility requirements and from every obligation attached to them. The reasoning is in the recitals, which say that making a microenterprise even carry out the disproportionate burden assessment would itself be disproportionate. The exemption is for services only. A microenterprise dealing in products gets lighter obligations rather than a clean exit.

What it technically requires

Meet the standard, which in practice means WCAG 2.1 Level AA through UNE-EN 301549. Article 3.2 spells out what counts as content, and the list is broader than most people assume. It covers text and non-text information, downloadable documents and forms, pre-recorded time-based media, two-way interaction, digital form processing, and the completion of identification, authentication, signature and payment processes. Payment and signature flows are named in the decree itself. That is unusual, and it is the part a store owner should read twice. Article 5.3 then adds a nudge past the minimum, asking covered entities to raise accessibility above the minimum level wherever they can.
Publish an accessibility statement using Spain's official model, and update it at least once a year whether or not the site changed. That annual floor is a hard rule, not a suggestion tied to redesigns. The statement has to be reachable from every page of the site, through a link labelled Accesibilidad or the equivalent in the page's own language. For a mobile app it goes on the developer's website beside the download link, or with the store listing. Article 7 handles disproportionate burden. The statement is where you record which requirements you cannot meet, and where you offer accessible alternatives if there are any.
Answer requests for accessible information and complaints within 20 business days. You can stop that clock once, by asking the person for clarification, and they get 10 business days to supply it. If the request is refused, or the person disagrees with your answer, or your answer does not meet what the decree requires, they can start a reclamación. Silence for 20 business days is itself enough to trigger one. The unit handling a reclamación has a maximum of two months to respond. Your accessibility statement has to name that unit and link to the system for making a claim.
Spain's technical bar updates itself, so the document to watch is the Official Journal rather than the decree. Article 6 gives you the presumption of conformity for harmonized standards whose references are published there, and where no reference has been published it names EN 301 549 as the fallback. Article 6.4 is the wiring most readers miss. A change to that published reference applies directly, with nobody amending Spanish law to make it happen. The reference in force is EN 301 549 V3.2.1, published in March 2021 and applying since February 12, 2022, which Spain publishes as UNE-EN 301549 and which carries WCAG 2.1 Level AA. A revision moving the web clauses to WCAG 2.2 is drafted and working through ETSI's process, with no published version number and no date attached to it. On the day it is cited, your requirement moves. That is the whole argument for testing against WCAG 2.2 Level AA now rather than waiting to be told.
If you are a public body, two duties sit inside the organization rather than on the website. Article 16 makes you designate the unit responsible for compliance, which in the General State Administration means naming it at the level of each department's Subsecretaría. Article 17 makes you review accessibility at the design stage and again before the site or app goes live, then keep reviewing it once it is running. In Spain, testing before launch is the law. It is not a nice idea somebody had.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

This law expects a published accessibility statement, and regulators check for it first. Generate yours free →

How it is enforced

Spain enforces the public sector rules through monitoring and complaints rather than private lawsuits, so you will not see the volume of website litigation the United States produces. The Ministerio de Política Territorial y Función Pública monitors and reports to the European Commission every three years, starting from December 2021. Those reports are published in an accessible format. It also holds the sharpest tool in the decree. It can run random sample checks on whether your own accessibility review reports are accurate. Marking your own homework is allowed. Being audited on the marking is the part people forget.

On the EAA side, Ley 11/2023 puts surveillance, enforcement and sanctions in chapter XI, and breaches are sanctioned under whatever sectoral legislation covers the sector. Where sectoral law does not cover it, the general disability rights sanctions regime applies as a backstop, and that regime runs from €301 to €1,000,000. Minor infringements are capped at €30,000, serious at €90,000, and very serious reach €1,000,000, with anything above €300,000 needing prior approval from the Council of Ministers. Read those as the supplementary scale. They are not the EAA fine in Spain, because which regime bites depends on your sector. And no Spanish enforcement action or fine under Ley 11/2023 could be found, so the numbers are a ceiling rather than a record.

For most businesses the practical risk in Spain is not a courtroom. It is a complaint that triggers a monitoring review, or a public contract you lose because the accessibility statement attached to your bid does not survive a look.

Key dates

Sep 20, 2018The decree comes into force, and with it the duty on public sector websites. Spain staged the complaints machinery, not the duty
2019 to 2020The deferred communication, request and complaint provisions come into effect, one and two years on
Jun 23, 2021Public sector mobile apps in scope
Jun 28, 2025European Accessibility Act applies to covered private services

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.