Spain · ES
Spain accessibility law: RD 1112/2018 + Ley 11/2023 explained
Spain transposed the Web Accessibility Directive (RD 1112/2018) and the EAA (Ley 11/2023). Compliance is monitored by the OAW, which publishes periodic reports on public-sector conformance.
- Primary law
- Real Decreto 1112/2018 + Ley 11/2023
- In force from
- 28 June 2025
- Standard
- WCAG 2.1 Level AA via EN 301 549
- Enforcement
- OAW (Observatorio de Accesibilidad Web) and consumer protection bodies
Who has to comply
Public-sector sites since 2018; private-sector consumer services from 28 June 2025.
If your service reaches consumers in Spain, EAA enforcement applies the same way it does to a domestic provider. The "country of consumption" rule means a Shopify store run from outside the EU but selling into Spain is covered. There is no carve-out for non-EU sellers.
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.
OAW (Observatorio de Accesibilidad Web) and consumer protection bodies runs the audits. They start with the largest covered services and move down. The first cycle of EAA audits in 2025–2026 will focus on visible non-compliance — missing accessibility statements, obvious WCAG violations on the homepage, lack of feedback channel — because those are cheap to detect. Deep technical audits come later.
Most enforcement starts with a complaint or a routine sweep. The first signal is usually a written notice giving you 30–60 days to remediate before fines kick in.
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
Frequently asked questions
Does the law apply to apps as well as websites?
Yes — RD 1112/2018 explicitly covers mobile apps published by covered entities. The EAA broadens this to consumer apps.
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