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
RD 1112/2018 + Ley 11/2023 sets the technical bar at WCAG 2.1 Level AA via EN 301 549. On top of it, Real Decreto 1112/2018 + Ley 11/2023 lists these operational duties:
- 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.
Reading the RD 1112/2018 + Ley 11/2023 at the source
The law is cited as Real Decreto 1112/2018 + Ley 11/2023. Enforcement: OAW (Observatorio de Accesibilidad Web) and consumer protection bodies. Key date: 28 June 2025. For the exact wording, read the official reference for Spain listed under Sources below.
Sources
- OAW guidance
- European Accessibility Act (Directive (EU) 2019/882) · European Commission
Links checked 12 October 2026. Not legal advice. Methodology · About Certvo
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.