European Accessibility Act (EAA) in Spain – All the Key Details

Trying to make sense of the European Accessibility Act (EAA) in Spain? With each country putting its own spin on the rules, it’s easy to feel overwhelmed or unsure where and how to start. Don’t worry – we’ll explain everything clearly, so you know exactly what to do.

In this post, we break down everything you need to know about the EAA in Spain, including who needs to comply, key exemptions, enforcement, deadlines, and penalties for non-compliance. By the end, you’ll have complete clarity.

How Is the EAA Implemented in Spain?

Spain transposed the European Accessibility Act (EAA) into national law through Ley 11/2023, enacted on 8 May 2023. This law sets the legal framework, outlining who must comply, what must be accessible, and the penalties for non-compliance.

Unlike Germany, Spain does not have a separate regulation detailing how to meet Ley 11/2023. Businesses seeking to ensure compliance are advised to refer to EN 301 549 for technical details on meeting EAA requirements.

Who Needs to Comply with the EAA in Spain?

Ley 11/2023, Spain’s EAA transposition, applies to private-sector businesses offering consumer-facing products and services in Spain.

The following sectors must comply with accessibility requirements:

• Websites and mobile applications: Businesses offering e-commerce platforms, banking apps, media streaming services, and online booking systems must ensure their websites and apps are accessible.
• Digital service providers: Companies providing online marketplaces, financial services, telecommunications platforms, and transport booking systems must meet accessibility standards.
• Manufacturers of physical products: Producers of consumer electronics, ATMs, ticketing machines, and self-service kiosks must design their products to be accessible.
• Electronic communications and media services: Television broadcasters, streaming platforms, and telecom service providers must offer accessibility features such as subtitles, audio descriptions, sign language interpretation, and screen reader compatibility where required.

Who Is Exempt from the EAA in Spain?

Certain exemptions exist under Ley 11/2023, including:

• Micro-enterprises: Businesses with fewer than 10 employees and ≤ €2 million turnover are automatically exempt from service-related accessibility requirements but must still comply if they manufacture physical products.
• Disproportionate burden clause: If making a product or service accessible would cause excessive costs or technical difficulties, businesses can apply for an exemption by submitting proper documentation for approval.
• Fundamental change exception: If accessibility changes would alter the product’s core function (e.g., making a tactile-only device fully screen-based), businesses can request an exemption with justification and regulatory approval.

What Are the Compliance Deadlines?

Spain follows the standard EAA compliance timeline:

• 28 June 2025: All new products and services introduced after this date must meet accessibility requirements.
• 28 June 2030: Products and services already on the market before June 2025 must be updated to comply or be discontinued.
• 28 June 2045: Self-service terminals (e.g., ATMs, ticket kiosks, and other self-service machines) installed before 2025 can remain in use for up to 20 years before requiring replacement with accessible versions.

Who Enforces the EAA in Spain?

Spain enforces its EAA transposition, Ley 11/2023, through:

• Autonomous Communities: Spain’s regional governments oversee enforcement within their territories.
• Consumer Protection Agencies: Handle complaints and accessibility disputes.
• National Market Surveillance Authorities: Conduct inspections and ensure compliance across sectors.

Consumers and disability advocacy organisations can file complaints, prompting investigations by these authorities. If a company fails to meet accessibility requirements, regulators can order corrective actions and impose fines.

What Are the Penalties for Non-Compliance?

Failure to comply with the EAA in Spain can result in:

• Minor infractions: Fines can reach up to €30,000.
• Moderate infractions: Penalties range from €30,000 to €150,000.
• Serious infractions: Fines up to €600,000.
• Product/service ban: Non-compliant products may be removed from the market, and services can be suspended.

How to Ensure EAA Compliance in Spain

To ensure EAA compliance in Spain, businesses must adhere to Ley 11/2023, which implements the European Accessibility Act. Compliance is primarily based on EN 301 549, as Spain does not have a separate technical regulation detailing how to meet the law.

Follow these key steps to meet Ley 11/2023 requirements:

Let’s now take a closer look at each step in detail.

Step 1: Identify Affected Products and Services

Determine which of your digital services and consumer-facing products must comply with EAA. These include websites, mobile apps, self-service terminals, e-commerce platforms, e-books, banking services, and consumer electronics.

Step 2: Conduct an Accessibility Audit

Evaluate your digital platforms and physical products against EN 301 549 and WCAG 2.2 Level AA to identify compliance gaps. Use WebYes to test your website against WCAG guidelines, and seek expert guidance for other digital and physical products.

Step 3: Develop a Compliance Roadmap

Put together a clear plan to tackle accessibility issues from the audit, focusing on the biggest barriers and keeping the compliance deadline in mind. Make sure everyone knows their role so things get done smoothly.

Step 4: Train Your Teams on Accessibility

Accessibility is a shared responsibility. Make sure your developers, designers, and product managers understand accessibility principles. Keep them up to date with ongoing training on EAA and Ley 11/2023, WCAG, and the POUR principles to keep accessibility front and centre.

Step 5: Document and Communicate Accessibility Compliance

For digital services, publish an accessibility statement outlining your compliance status and how users can report issues. For physical products, prepare technical documentation and apply the CE marking to show compliance with all relevant EU legislation, including accessibility.

Step 6: Implement Continuous Monitoring

Accessibility isn’t a one-time task – it’s an ongoing commitment. Use tools like WebYes to continuously test and monitor your digital services. Run regular reviews of both digital and physical products to ensure ongoing compliance and accessibility for all users.

How Can WebYes Help You Meet EAA Requirements in Spain?

WebYes can help you meet EAA compliance in Spain by making it easy to find and fix accessibility issues on your website – without all the confusion.

Here’s how we can help:

• Instant accessibility audits: Just enter your website URL, and WebYes will scan for WCAG 2.2 compliance issues.
• Actionable fixes: WebYes gives clear suggestions so you know exactly how to fix the accessibility issues.
• Continuous monitoring: Stay compliant over time with ongoing scans that catch new issues before they become real problems.

We’re here to help you meet Spain’s EAA requirements with clarity – and make your website accessible to everyone. Run a free accessibility audit to see where your site stands, identify key issues, and get clear guidance on what to fix next.