Spain's accessibility law (Ley 11/2023)

What it is, in one sentence

Ley 11/2023 of 8 May is Spain’s version of the European Accessibility Act. If your company sells to consumers in Spain in one of the sectors it lists, your website and app have to be usable by people with disabilities from 28 June 2025.

The law is long and bundles unrelated subjects (skilled migration, notaries, tax). What matters here is Title I, Articles 1 to 31, plus two provisions at the end: the third additional provision, on websites, and the single transitional provision, on deadlines.

How it differs from the EU Directive

Spain did not copy the Directive word for word. Three differences matter for a website:

More sectors. On top of the EU list (e-commerce, banking, telecoms, transport, e-books), Article 2.2 adds the websites and apps of electricity, water and gas suppliers, of travel agencies and tour operators, and social networks.

A named technical standard for websites. The third additional provision requires in-scope websites to meet “at minimum, the medium level” of accessibility criteria, with UNE 139803 as the reference. That is the Spanish standard that mirrors WCAG, so the practical target is WCAG level AA.

Less time for self-service terminals. ATMs and kiosks already in place can stay in use until the end of their economic life, but for no more than ten years after they were put into service. The Directive allowed up to twenty.

What a company with a website has to do

If your service is in scope, the law asks for four things.

1. The service meets the Annex I requirements. On a website, that translates into the four WCAG principles: content can be perceived, operated and understood, and works with assistive technology such as screen readers.
2. You explain how you comply (Article 13). In your general terms or an equivalent document, with a description of the service and how you keep it accessible, in accessible formats.
3. You train your staff (Article 15). People who serve customers need to know how to use and explain accessible products and services.
4. You keep it that way. If you outsource part of the service, the responsibility stays with you (Article 14.2). If you claim disproportionate burden, you must document and review it.

Which parts of your site to check first

The law does not say where to start, but the risk is not spread evenly. Start with the journey that turns a visitor into a customer:

• Checkout or sign-up form. Fields without labels, errors shown only in red, buttons that do not respond to the keyboard.
• Menu and search. If they cannot be used without a mouse, nothing else matters.
• Product or plan pages. Images without alternative text and prices in low contrast.
• Cookie banner. It is often the first thing keyboard focus reaches, and sometimes it does not let go.

An automated analysis gives you the list of barriers on these pages in minutes, ordered by severity. It is the sensible starting point before deciding what to fix first.

Fines

The law does not set its own amounts. Article 30 points to the sector legislation of each field and, where that is silent, to the penalty regime of the General Law on the rights of persons with disabilities (Royal Legislative Decree 1/2013). That regime ranges from 301 euros to 1,000,000 euros, depending on severity, intent, the number of people affected and turnover, among other criteria.

Beyond fines, Article 29.2 lets consumers, associations and disability organizations go to the authorities and the courts to demand compliance.

What this page is not

It is a summary of the law and its official sources, not legal advice. If your case is borderline (for example, you are unsure whether you are a microenterprise or whether your service is for consumers), confirm it with a lawyer. What we can do is tell you which barriers your site has today and how to fix them.