EAA in Spain (Ley 11/2023): what your online store must do

Spain is one of the largest e-commerce markets in the European Union. If you sell there, accessibility is no longer optional: Ley 11/2023 transposes the same European directive as the French and German laws, but with its own sanctions architecture, its own authorities and its own information duty. Here is what changes in concrete terms.

Which law: Ley 11/2023

Ley 11/2023, de 8 de mayo, transposing European Union directives on, among other things, the accessibility of certain products and services, is the Spanish transposition of Directive (EU) 2019/882 — the European Accessibility Act (EAA). It is the exact Spanish equivalent of what Ordinance No. 2023-859 does in France. It was published in the Boletín Oficial del Estado (BOE No. 110) on 9 May 2023, but the accessibility obligations (Title I) apply only from 28 June 2025, in line with the European timetable.

E-commerce is named explicitly: art. 2.2, point f) lists "servicios de comercio electrónico" among the covered services, alongside consumer banking, electronic communications, passenger transport, e-books and audiovisual media on demand. The law defines these as services provided at a distance, through websites and applications, by electronic means and at the individual request of a consumer with a view to concluding a contract (Anexo VII).

The technical standard: EN 301 549 / WCAG 2.1 AA

Ley 11/2023 does not reinvent the technical criteria. As everywhere in the Union, a service's compliance is presumed when it follows the harmonised standards whose references have been published in the Official Journal of the European Union (art. 17). For web services, the relevant harmonised standard is EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, level AA.

In practice, the requirements are the same as in France or anywhere else in Europe: sufficient colour contrast, text alternatives for images, keyboard navigation, properly labelled forms, a page structure readable by assistive technology. For e-commerce, the law additionally stresses the accessibility of identification, security and payment functions (Anexo I). A site already built to WCAG 2.1 AA satisfies the core of the law.

How much: the sanctions regime (by reference to RDL 1/2013)

This is where Spain differs from Italy or Germany. Ley 11/2023 does not create its own euro fine scale: it organises the monitoring of compliance and refers, for sanctions, to the existing disability regime — Real Decreto Legislativo 1/2013 (Ley General de derechos de las personas con discapacidad), article 83. The applicable brackets are therefore those of that text:

Beyond the fine, the most immediate lever is operational: the supervisory authority can require the service to be brought into compliance. For an online store, having your checkout flagged on the Spanish market often weighs more heavily than the size of the penalty itself.

Who enforces it? The supervisory authorities

Unlike Italy (AgID) or Germany (MLBF), Spain does not designate a single national authority. Monitoring of services is entrusted to the supervisory authorities designated by the Autonomous Communities (and by the cities of Ceuta and Melilla). Where no competent authority has been designated, a Technical Support and Coordination Unit (Unidad Técnica de Apoyo y Coordinación), within the General State Administration, acts on a residual basis and serves as the contact point for complaints.

An inspection can be triggered by a complaint — for example a person with a disability who cannot complete a purchase — just as much as by an own-initiative check.

The mandatory document: accessibility information (art. 13)

Beyond technical accessibility, the service provider must provide information about the accessibility of its service, to be included in its general terms and conditions or an equivalent document. This is the obligation in art. 13 of Ley 11/2023, which requires at minimum: (a) a general description of the service in accessible formats, (b) the explanations needed to understand how it works, and (c) a description of how the service and its monitoring meet the applicable accessibility requirements. This information must be kept up to date for as long as the service is provided.

As in France, this document is immediately verifiable: an inspector does not need to audit dozens of technical criteria to note that it is missing. It is the easiest breach to establish.

The user's avenues of recourse

A user who hits a barrier has a multi-step path:

• first, the feedback mechanism that the operator must provide for reporting an inaccessibility;
• failing a satisfactory response, a complaint or report to the competent supervisory authority (or to the Technical Support and Coordination Unit as the contact point);
• the arbitration channels on equal opportunity, non-discrimination and accessibility, or consumer-protection procedures;
• in parallel, the ordinary judicial route, notably under the rules on equal opportunity and non-discrimination of persons with disabilities (RDL 1/2013).

For the business, the stakes are clear: each of these routes can bring your service to the authority's attention. Better to be compliant before the first complaint than after it.

The mistake to avoid: "one-click accessibility" overlays

Widgets such as accessiBe or UserWay promise automatic compliance through a single line of code. They do not make a site compliant. Their real effectiveness is disputed by disability organisations; in the United States, the FTC fined accessiBe one million dollars in 2025 over compliance claims found misleading. Above all, an overlay does not fix your site's source code and does not produce the accessibility information required by art. 13 of Ley 11/2023.

The defensible path is the opposite: audit the site, fix what can be fixed, and publish honest accessibility information that documents the real state and the action plan.

How to comply, in practice

1. Audit. An automated technical scan (WCAG 2.1 AA) catches part of the non-conformities — contrast, image alternatives, structure, forms. It does not replace a full manual audit, but it establishes a factual, quantified baseline.
2. Fix the priority items — often few in number and inexpensive (colour contrast, form labels, keyboard navigation).
3. Publish the accessibility information (art. 13), with an accurate conformance status and the avenues of recourse.
4. Keep it up to date: compliance degrades with every release. A periodic re-scan keeps you from drifting.

Frequently asked questions