Spain's commitment to digital accessibility is defined by a multi-layered legal framework that combines long-standing national laws with the comprehensive directives of the European Union. For any organization operating a digital presence in Spain, understanding these laws is crucial for compliance. The two most significant pieces of legislation are Royal Decree 1112/2018 and the more recent Law 11/2023.
Royal Decree 1112/2018: The Public Sector Mandate
This Royal Decree is Spain's national transposition of the EU's Web Accessibility Directive (WAD). Its primary focus is on the public sector, mandating that websites and mobile applications of government bodies—including national, regional, and local administrations—must be accessible.
Key requirements under this decree include:
- Conformance with the European technical standard EN 301 549, which incorporates WCAG 2.1 Level AA.
- The publication of a detailed and regularly updated accessibility statement (declaración de accesibilidad).
- Providing a user feedback mechanism for reporting accessibility issues.
This decree also indirectly affects private companies, as any business providing digital products or services to public sector entities must also meet these accessibility standards to secure government contracts.
Law 11/2023: Extending Accessibility to the Private Sector
Law 11/2023 is Spain's transposition of the European Accessibility Act (EAA). Coming into full effect on June 28, 2025, this law significantly expands accessibility obligations to the private sector. It applies to a broad range of products and services offered to consumers in Spain, including:
- E-commerce websites and apps
- Consumer banking services
- Computers, smartphones, and operating systems
- E-book readers
- Passenger transport services
This law makes digital accessibility a legal requirement for most businesses interacting with Spanish consumers. The technical standard for compliance is, once again, EN 301 549 (and by extension, WCAG 2.1 AA).
The Role of UNE 139803:2012
Prior to the current EU-aligned framework, Spain's national standard for web accessibility was UNE 139803, first established in 2004 and updated in 2012. This standard was based on WCAG 2.0 Level AA and laid the groundwork for accessibility in Spain, particularly within the public sector. While the newer Royal Decree 1112/2018 and EN 301 549 have superseded it as the primary legal benchmarks, the principles of UNE 139803 were foundational to Spain's early adoption of digital accessibility.
Enforcement and Penalties
The consequences for non-compliance in Spain are severe. Under a related law, Royal Legislative Decree 1/2013, organizations can face :
- Fines ranging from €301 for minor infractions up to €1 million for very serious, repeated violations.
- Loss of eligibility for public funding or subsidies.
- In extreme cases, the partial or complete suspension of the company's operations.
Ensuring Compliance in the Spanish Market
For businesses operating in Spain, the message is clear: digital accessibility is a legal requirement with serious financial and reputational consequences. Adhering to the WCAG 2.1 Level AA standard is the most direct path to ensuring compliance with both Royal Decree 1112/2018 and Law 11/2023.
Wawsome’s platform is engineered to help businesses meet these rigorous standards. Our AI-powered tools provide continuous monitoring and remediation to ensure your digital assets are compliant, accessible, and ready for the Spanish market.