Spain accessibility law: RD 1112/2018 + Ley 11/2023 explained

Who has to comply

Public-sector sites since 2018; private-sector consumer services from 28 June 2025.

Spain is a major EU market with a large tourist- and export-facing e-commerce sector, so many foreign stores sell into it in euros. Ley 11/2023 applies to those sellers under the country-of-consumption principle, and Spain's very-serious-infringement ceiling of €600,000 is among the higher fixed caps in the EU. A non-EU seller shipping to Spanish consumers should treat the OAW accessibility statement template as mandatory, since a missing or non-conforming statement is the easiest thing for the regulator to spot on a foreign-run site.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA via EN 301 549. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, Spain requires the following operational items, which auditors check first because they are simple to verify:

• WCAG 2.1 AA via EN 301 549

• Accessibility statement following the OAW template

• Feedback and complaint procedure

• Triennial technical audit for public-sector sites

Penalties and how enforcement actually works

Up to €600,000 (very serious infringements) under Ley 11/2023.

Spain monitors accessibility primarily through the Observatorio de Accesibilidad Web (OAW), which runs periodic automated and manual sampling and publishes conformance reports, backed by the consumer-protection authorities for private-sector sanctions. The OAW model is sampling- and observatory-led rather than purely reactive: it periodically crawls covered services and expects the OAW-format statement and a working complaint procedure. Public-sector sites face a triennial technical audit, and the same methodology increasingly shapes how private-sector conformance is checked.

Practical first steps for a Spain site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

• Run a baseline scan to know your current score

• Fix critical and serious issues in priority order — these are the ones cited in complaints

• Publish a public accessibility statement on a stable URL (Spain regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions