European Accessibility Act and Law 11/2023

What it is

The European Accessibility Act (EAA), known in Spanish as the Acta Europea de Accesibilidad, is Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services. Its aim is for people with disabilities to be able to use key products and services on an equal basis throughout the European Union.

In Spain, it is transposed by Law 11/2023 of 8 May. Its requirements have applied since 28 June 2025.

Which services it covers

It applies to services provided to consumers:

• E-commerce: selling products or services at a distance through a website or app.
• Consumer banking services.
• Air, bus, rail and waterborne passenger transport: websites, apps, electronic tickets, travel information and self-service terminals. For urban, suburban and regional transport, only self-service terminals are covered.
• E-books and dedicated software for reading them.
• Electronic communications services, such as phone services or internet access.
• Services providing access to audiovisual media services, such as TV platforms.

In Spain, the law also extends to the websites and apps of electricity, water and gas suppliers, of travel agencies and tour operators, and of social networks.

The Directive also covers products, such as computers, smartphones, ATMs, ticket machines, e-readers and television equipment. At SiteNorma, we focus on the websites and apps of services.

Who is exempt

Microenterprises that provide services are exempt from these requirements. A microenterprise has fewer than 10 people working for it and an annual turnover or annual balance sheet total of €2 million or less.

Many small online shops are microenterprises. If you are not sure whether this is your case, use our questionnaire Does the EAA apply to me? Even if your business is exempt, making your website accessible is still a good idea.

What you need to do if it applies to you

1. Meet the accessibility requirements in Annex I to the Directive on your website, your apps and the service's other channels.
2. Publish accessibility information about the service (Annex V to the Directive and Article 13.2 of Law 11/2023) in your general terms and conditions or an equivalent document. It must explain how the service works and how it meets the requirements, be available in written and oral form, be accessible and be kept for as long as the service is in operation.
3. Maintain conformity when you change your website, and fix the failures you detect.
4. Document exceptions. If you invoke a disproportionate burden or a fundamental alteration of the service, you must assess it using the criteria in Annex VI, document the assessment, keep it and renew it at least every five years.

What it means for your website

The Directive requires the service to be perceivable, operable, understandable and robust. The usual technical reference is the EN 301 549 standard, which refers to the WCAG guidelines for the web:

• EN 301 549 v3.2.1, the version currently cited in the Official Journal of the EU, is based on WCAG 2.1 level AA.
• EN 301 549 v4.1.1, published by ETSI on 2 September 2026 and expected to be cited in the Official Journal in the fourth quarter of 2026, is based on WCAG 2.2 level AA.

Our practical advice is to work with WCAG 2.2 level AA now. For e-commerce, there are two more points: providing information about the accessibility of the products you sell when the responsible economic operator supplies it, and making identification, security and payment accessible.

Excluded web content

The Directive excludes some content of websites and apps:

• Pre-recorded time-based media published before 28 June 2025.
• Office files published before 28 June 2025.
• Online maps and mapping services, as long as the essential information in maps intended for navigation is provided in an accessible way.
• Third-party content that the service provider does not fund, develop or control.
• Archived content that has not been updated or edited since 28 June 2025.

Deadlines and transition period

• Since 28 June 2025, the requirements have applied to services.
• Until 28 June 2030, service providers can continue to provide their services using products they were already using lawfully before 28 June 2025.

Who enforces it and what the penalties are

Enforcement is the responsibility of the autonomous communities (Spain's regions). Royal Decree 143/2026 created a technical unit that coordinates this work and also receives complaints.

Law 11/2023 refers to the system of offences and penalties in Royal Legislative Decree 1/2013:

Penalty amounts

Type of offence	Fine
Minor	€301 to €30,000
Serious	€30,001 to €90,000
Very serious	€90,001 to €1,000,000

How SiteNorma helps you

SiteNorma cannot comply with the law for you, but it helps you at every step: it detects barriers with automated tests, guides you through the manual review, brings the results together in a compliance matrix and prepares a draft of the accessibility information about the service.

Official texts

• Directive (EU) 2019/882, on EUR-Lex
• Law 11/2023 of 8 May, in the BOE (Spain's Official State Gazette)
• Royal Legislative Decree 1/2013 of 29 November, in the BOE

General information, not legal advice. Last reviewed: 25 September 2026.