Yes, if you sell online to consumers and are not a micro-enterprise: Law 11/2023 on accessibility (Ley 11/2023) has applied to you since 28 June 2025. If you serve the public without selling on your website, like a law firm or a clinic, Royal Decree 193/2023 (Real Decreto 193/2023) applies to you. That will be from 2029 or, at the latest, before 2030. Below you will find a decision tree, the fines with their article and 15 checks you can do in 30 minutes without knowing how to code.
Three pieces of legislation decide whether your website has to be accessible
No law applies to every website at once. Three pieces of legislation split the obligation according to what you sell, to whom, and what money paid for the website.
- Law 11/2023, for services to consumers. It transposes the European Accessibility Act, Directive (EU) 2019/882. Its title I has applied since 28 June 2025 (eighteenth final provision). It covers, among others, e-commerce, banking, passenger transport, travel agencies and electricity, water and gas websites (art. 2.2).
- Royal Decree 193/2023, for any business open to the public. It requires private websites that offer goods or services to the public to meet levels A and AA (art. 14.2). It includes professional activities (art. 2.c). For private companies, the key dates are 2029 and 2030 (sixth final provision).
- Royal Decree 1112/2018 (Real Decreto 1112/2018), for websites paid for with public money. It is designed for the public sector. But it requires public authorities to impose its criteria on websites that receive public funding for their design or maintenance. Also on the websites of companies that manage public services (first additional provision).
One rule that many guides still cite no longer counts. It is the fifth additional provision of the LSSI, Spain’s Information Society Services Law, which applied to large companies in certain sectors. It was repealed on 10 May 2023 (sole repealing provision of Law 11/2023).
We always separate what is a legal obligation from what is good practice. When something is our interpretation and not the text of a law, we mark it as a cautious approach. What is our own method appears as our approach.
Decision tree: does the law apply to me?
Answer in order. You may end up with more than one obligation. It is also available as an interactive test, with an instant result.
1. Can a consumer buy, or sign up and pay, on your website or app? It also counts if you provide banking or telecommunications services to consumers. And if you are a travel agency, carry passengers or supply electricity, water or gas.
- Yes: go to question 2.
- No, or you only work with businesses: Law 11/2023 does not apply to you, because it only covers services to consumers (art. 2.2). Go to 3.
2. Are you a micro-enterprise? You are if you have fewer than 10 people and your annual turnover or balance sheet does not exceed €2 million (Law 11/2023, annex VII). It is enough for one of the two figures to stay within that limit.
Partner and linked companies count: the Directive requires genuinely meeting the European definition of an SME (recital 53).
- No: Law 11/2023 has applied to you since 28 June 2025. Continue with 3.
- Yes: if you provide services, you are exempt from this law (art. 3.3). Go to 3.
3. Was your website partly paid for with a grant, or do you provide services under an agreement with the public administration (servicios concertados)?
- Grant-funded website: the public administration must require you to meet the criteria of Royal Decree 1112/2018 (first additional provision). If it was paid for with the Kit Digital programme, the rules required the design to meet WCAG 2.1 level AA (Order ETD/1498/2021, annex IV).
- Service under an agreement with the administration, which is how we understand the case of a clinic with an agreement with the public health system. Royal Decree 193/2023 has applied to its new services since 1 January 2025. Existing ones had to be adapted before 1 January 2026 (sixth final provision).
- In both cases, continue with 4.
4. Can anyone hire you or buy from you? A shop, a law firm, a clinic or a tax and accounting firm, yes.
- Yes: Royal Decree 193/2023 applies to you. For your new services, your website must meet A and AA from 1 January 2029. For the services you already offer, it must be adapted before 1 January 2030. It does not exempt micro-enterprises, but it allows adjustments proportionate to your size and your costs (art. 2.e).
- No: we have not found a general rule that obliges you. Accessibility is good practice.
5. Do you have more than 100 employees or a turnover above €6,010,121.04? It counts if you also work in one of these sectors: telecommunications, financial services or insurance mediation, utilities, travel agency, passenger transport or retail (Law 56/2007 (Ley 56/2007), art. 2.2). If you run an insurance brokerage, also see what the law requires of its website.
- Yes: your website must also state the level of accessibility of your services, facilities and procedures (Royal Decree 193/2023, art. 14.3 and 14.4).
- If you reach 250 employees or €50 million in turnover and sell to consumers: your customer service must be accessible. The deadline is 28 December 2026 (Law 10/2025 (Ley 10/2025), arts. 2.2 and 15 and sole transitional provision).
Example
Take three businesses in Castellón:
- An online ceramics shop with 14 people that sells to individuals. Law 11/2023 has applied to it since 28 June 2025.
- A physiotherapy clinic with 6 people and a turnover of €600,000 that sells session packs on its website. It does e-commerce, but it is a micro-enterprise: it falls outside Law 11/2023. Royal Decree 193/2023 reaches it from 2029 or, at the latest, before 2030, or earlier if it has services under an agreement with the administration.
- A law firm with 4 lawyers and an informational website paid for with the Kit Digital. Law 11/2023 does not apply to it. The grant already required WCAG 2.1 AA, and Royal Decree 193/2023 reaches it just as it does the clinic.
Is an online appointment e-commerce?
It is a common question for many law firms and clinics. For Law 11/2023, e-commerce is a service provided at a distance, by electronic means and at the consumer’s request, “with a view to concluding a contract” with them (annex VII). The Directive clarifies that it covers the online sale of any product or service (recital 43).
Cautious approach:
- If the client pays for a consultation, a pack or a subscription on the website, it is e-commerce.
- If they book an appointment without paying, you are in a grey area. If you are not a micro-enterprise, treat it as e-commerce.
- If they only leave their details so that you can call them, no contract is concluded on the website.
We have not found any official Spanish guidance that draws this line.
Law 11/2023 already applies: what it has required since June 2025
If you are covered, Law 11/2023 asks five things of you.
- A genuinely accessible website. You must design and provide the service in an accessible way (art. 13.1), with a website that is perceivable, operable, understandable and robust (annex I, section III). At a minimum, at the “medium level” of generally recognised criteria (third additional provision), which in practice is taken to mean AA. In e-commerce, identification and payment too (annex I, section IV).
- Information about your accessibility. Your general terms and conditions, or an equivalent document, must explain how your service complies (art. 13.2). How this fits with your other legal texts is covered in legal notice, privacy and cookies. This information must be provided in writing and orally, in an accessible format and kept up to date (art. 13.4).
- Staff training. Those who serve and sell must know how to use and explain accessible services (art. 15).
- Correct and report. If you detect that you do not comply, you must fix it and inform the authorities (art. 13.7).
- Justify exceptions. You can claim a disproportionate burden, but it must be documented with the criteria in annex V and renewed at least every 5 years (art. 16). If you received funding to improve accessibility, you cannot claim it (art. 16.6).
Cautious approach: publish an “Accessibility” page linked from the footer of every page and refer to it from your general terms and conditions. Follow the model of the “accessibility statement” that Royal Decree 1112/2018 imposes on the public sector. Explain which parts are not accessible, why, and how to report a problem (art. 15).
Videos and office documents published before 28 June 2025 are excluded (art. 2.4). Third-party content that you neither fund nor control does not count either, and nor do archives that have not been updated since that date. If you update an archive, it is no longer excluded.
You do not have until 2030 to adapt your website
Many guides say that services that already existed have until 2030. That is not what the law says.
The sole transitional provision allows you to keep using, until 28 June 2030, the products you were already using to provide the service, such as equipment or a terminal. It also allows contracts signed before June 2025 to continue unchanged, for a maximum of 5 years.
The Directive explains it: the requirements apply to services provided after its date of application (recitals 101 and 102). Cautious approach: if the law covers you, your website had to comply from 28 June 2025. The 2030 deadline that does exist is the one in Royal Decree 193/2023 for private services you already offered.
Not complying can cost from €301 to €1,000,000
Law 11/2023 has no fines of its own. It refers to sector-specific legislation and, where that legislation makes no provision, to title III of the General Law on the rights of persons with disabilities (Ley General de derechos de las personas con discapacidad) (art. 30). Royal Decree 193/2023 refers to the same title (art. 15).
| Infringement | What conduct, for example | Fine |
|---|---|---|
| Minor | Failing to meet formal obligations (art. 81.2) | From €301 to €30,000 (art. 83) |
| Serious | Failing to meet the accessibility requirements in a way that limits the use of a service by persons with disabilities (arts. 81.3.b and 95.3.e) | Up to €90,000 (art. 83.3) |
| Very serious | Failing to meet them in a way that prevents access, or ignoring repeated requests (arts. 95.4.f and 81.4.b) | Up to €1,000,000 (art. 83.1) |
Serious and very serious infringements can also carry a ban on applying for official aid for a period of up to 1 or 2 years (art. 85.1).
Who monitors compliance. Each autonomous community designates its surveillance authority (Law 11/2023, art. 27.3). Since 28 February 2026 there has also been a national coordination unit, the UTAC (Royal Decree 143/2026 (Real Decreto 143/2026)).
It reports to the Directorate-General for the Rights of Persons with Disabilities. It receives complaints and acts as the authority where none has been designated (art. 3.g and 3.h). The Ministry explains how to file a complaint on its UTAC page.
As of 2 October 2026 we have not found the designation of the Valencian authority published. And not everything depends on an inspection: any consumer, association or body with a legitimate interest can go to the authorities and the courts (art. 29.2).
The case worth knowing. In 2024, the National High Court (Audiencia Nacional) upheld the penalty imposed on Vueling over the accessibility of its website: €90,000 and 6 months without being able to apply for official aid (Judiciary press release). A CENTAC report concluded that the website fully met 4 of the 38 applicable requirements.
The penalty was imposed under the previous rules, but under the same article 95.3.e that applies today where there is no sector-specific rule.
In the Valencian Community, Law 8/2024 on universal accessibility (Ley 8/2024) has its own scale, from €300 to €300,000 (art. 93). It applies it to what it regulates, such as the websites of companies holding public service concessions (arts. 21.2.d and 22.2).
The bar is WCAG 2.1 AA, and WCAG 2.2 arrives with the new European standard
The national rules that apply to businesses do not cite WCAG by name. They refer to the “medium level” or to levels A and AA of a Spanish standard, UNE 139803.
The Royal Board on Disability (Real Patronato sobre Discapacidad) specifies the reference in its guide for micro-enterprises: UNE-EN 301 549, which includes WCAG 2.1 at levels A and AA. Its 2026 guide links it to Royal Decree 193/2023 (Accessibility in Consumer Affairs).
What gives legal certainty is the harmonised standard. If you comply with a standard whose reference has been published in the Official Journal of the EU, you are presumed to comply with the law (Law 11/2023, art. 17). For public sector websites, that standard is EN 301 549 V3.2.1.
The 2026 change is EN 301 549 V4.1.1, adopted on 24 August and published in September. It is the first version prepared for the European Accessibility Act and it is aligned with WCAG 2.2.
It will give a presumption of conformity when the Commission publishes its reference in the Official Journal. We have not found that publication as of today.
Cautious approach: if you are redesigning, ask for WCAG 2.2 AA in writing. The W3C explains that content that conforms to 2.2 also conforms to 2.1 (WCAG overview). The technology does not decide on its own: a website built in Framer, WordPress or custom code may or may not comply depending on how it is built.
Checklist: 15 checks in 30 minutes, no coding needed
Choose 3 pages: the home page, a service or product page and the contact page or the basket. Install the WAVE extension or paste each address into wave.webaim.org. If you have an accessibility widget, turn it off before you start.
Each row links to the WCAG 2.2 criterion on the W3C website, in English. The list follows the first review proposed by the W3C itself (Easy Checks), adapted to an SME website.
| # | What you do (minutes) | Passes if | WCAG criterion |
|---|---|---|---|
| 1 | Review WAVE’s contrast errors and check light grey text and text over photos by eye (2) | Contrast of at least 4.5:1 for normal text and 3:1 for large text | 1.4.3 |
| 2 | Look in WAVE for images without alternative text and read the alternative texts that do exist (3) | Every image that carries information has a useful description; decorative ones, none | 1.1.1 |
| 3 | Put the mouse aside. Move through the page with Tab and Shift+Tab, and use Enter and the space bar. If you sell, go all the way to payment (4) | You can reach everything and get out of everything, including pop-up windows | 2.1.1 and 2.1.2 |
| 4 | During that run-through, notice whether you can see where you are (1) | A box or underline is always visible, and it is not hidden by the sticky header or the cookie banner | 2.4.7 and 2.4.11 |
| 5 | Open your contact or booking form and start typing (2) | Each field has a visible name that does not disappear when you type | 3.3.2 and 1.3.1 |
| 6 | Submit the form empty or with a mistyped email (2) | The message says which field is wrong and how to fix it, in text and not just in red | 3.3.1, 3.3.3 and 1.4.1 |
| 7 | Zoom in with Ctrl and + (Cmd and + on a Mac) up to 200% and then up to 400% (3) | At 200% everything can be read without cut-offs; at 400% the content reflows without a horizontal scroll bar, except tables, maps or charts | 1.4.4 and 1.4.10 |
| 8 | Read the browser tab title on each page (1) | Each page has a different title that says what it is | 2.4.2 |
| 9 | Review WAVE’s alerts about headings and check whether each section has its heading (2) | There is one main heading and the sections hang from it in a logical order, with no empty headings | 1.3.1 and 2.4.6 |
| 10 | Look for repeated “click here” and “read more” links and icons without text, such as the magnifying glass or the basket; WAVE flags empty links and buttons (2) | Every link and every button says where it leads or what it does | 2.4.4 and 4.1.2 |
| 11 | Check whether WAVE warns that the page language is missing (1) | The page declares its language | 3.1.1 |
| 12 | Play your main video (2) | It has captions, and nothing plays sound on its own for more than 3 seconds without a way to stop it | 1.2.2 and 1.4.2 |
| 13 | Look at carousels, animated banners and scrolling text (1) | Anything that moves on its own for more than 5 seconds can be paused or stopped | 2.2.2 |
| 14 | Open your most downloaded PDF, such as the menu, the price list or the brochure, and try to select the text (2) | The text can be selected and copied: it is not a scanned image | 1.1.1 |
| 15 | Open the website in a private window and handle the cookie banner using only the keyboard (2) | You can accept, reject and configure with the keyboard, and the banner text is easy to read | 2.1.1 and 1.4.3 |
Passing all 15 does not mean your website is accessible. The W3C warns about this in its own list: these checks cover only a few problems, and a page can pass them and still have significant barriers. They do tell you whether you are close or far.
Our approach: failures in points 3 to 7 are usually in the website’s template or theme. Those in points 2, 12 and 14 usually come from how content is uploaded, and are fixed by training whoever publishes it.
An accessibility widget does not make your website accessible
None of the rules in this article mentions widgets or overlays as a way to comply. What they ask is to design and provide the service in an accessible way (Law 11/2023, art. 13.1), and that lives in the code and the content.
The clearest warning came from the United States. In April 2025, the Federal Trade Commission approved the final order against accessiBe, which had to pay $1 million (FTC).
The company advertised that its plugin made any website WCAG-compliant. For the FTC, those claims were false, misleading or unsubstantiated.
The W3C sums it up like this: evaluation tools cannot determine accessibility, they can only help you assess it (W3C).
Automated tools find errors, but they certify nothing
These four tools check your website for you and find problems in the code. None of them can tell you whether your website is accessible.
| Tool | What it does | What it cannot tell you |
|---|---|---|
| WAVE, by WebAIM | Flags contrast errors, images without alternative text, unlabelled fields and empty headings on your page | Whether the alternative text is appropriate or whether everything works with the keyboard. Its help says so: only a human can determine whether a website is accessible |
| axe DevTools, by Deque | Its free extension runs automated tests, one page at a time | Guided tests are part of the paid version |
| Lighthouse, by Google | Open-source tool built into Chrome. It gives an accessibility score weighted by the impact that axe assigns (scoring). You will also see it in PageSpeed Insights | Its own report warns that automated detection only finds some of the problems and does not guarantee accessibility (official report text) |
| W3C Validator | Free service that checks whether the HTML is well written | WCAG 2.2 removed the code validation criterion (4.1.1). Valid HTML is not the same as an accessible website |
A score of 100 in Lighthouse means your page passes its automated tests. Nothing more. Keyboard use, the meaning of alternative texts and the quality of captions are checked by hand, which is what the checklist above does.
What to do on Monday
- Go through the decision tree and note which legislation applies to you and from what date.
- Do the checklist on your 3 key pages. Note each failure with a screenshot and the page where it happens.
- If your website was built with the Kit Digital, ask the digitalisation agent (agente digitalizador) for proof that it met WCAG 2.1 AA, as the rules required (annex IV).
- If Law 11/2023 covers you, publish the “Accessibility” page, link it from the footer and from your general terms and conditions (art. 13.2) and provide a channel for reporting problems.
- Change how you publish from today. Alternative text on every image, captions on every video and PDFs with real text. What you publish from 28 June 2025 onwards is no longer excluded (art. 2.4).
- If you have an accessibility widget, do not count on it to comply.
- If you are going to rebuild the website, ask for WCAG 2.2 AA in the quote and a manual testing report on delivery. To avoid losing rankings along the way, follow the plan for a redesign without losing rankings.
If you want us at NOR studio to review your website with this checklist and tell you what fails against level AA, let’s talk about your case. Confirm with your adviser which legislation applies to you. And if it is time to rebuild it, make accessibility part of the web design brief from the first sketch.
Sources consulted (32)
- BOE: Law 11/2023 of 8 May, transposing EU Directives on the accessibility of certain products and services (Ley 11/2023; arts. 2, 3, 13, 15, 16, 17, 27 to 30, annexes I and VII, third additional provision, sole transitional provision, sole repealing provision and eighteenth final provision)
- OJEU (BOE copy): Directive (EU) 2019/882 on the accessibility requirements for products and services (European Accessibility Act), recitals 43, 53, 101 and 102
- BOE: Royal Decree 193/2023 on the basic accessibility conditions for access to and use of goods and services available to the public (Real Decreto 193/2023; arts. 2, 3, 6, 14, 15 and sixth final provision)
- BOE: Royal Decree 1112/2018 on the accessibility of public sector websites and mobile applications (Real Decreto 1112/2018; art. 15 and first additional provision)
- BOE: Law 34/2002 on information society services (LSSI), fifth additional provision, repealed
- BOE: Royal Legislative Decree 1/2013, General Law on the rights of persons with disabilities (Real Decreto Legislativo 1/2013; arts. 81, 83, 85, 95 and 96)
- BOE: Royal Decree 143/2026, creating the Technical Support and Coordination Unit for accessibility surveillance authorities (Real Decreto 143/2026)
- BOE: Law 56/2007 on measures to promote the information society (Ley 56/2007; art. 2.2)
- BOE: Law 10/2025 regulating customer service (Ley 10/2025; arts. 2, 15 and sole transitional provision)
- BOE: Law 8/2024 on universal accessibility of the Valencian Community (Ley 8/2024; arts. 21, 22 and 93)
- BOE: Order ETD/1498/2021, rules of the Kit Digital programme (annex IV)
- BOE: Order TDF/435/2024, amending the Kit Digital rules and keeping the WCAG 2.1 AA requirement
- ETSI, CEN and CENELEC: EN 301 549 V4.1.1 (2026-09), accessibility requirements for ICT products and services
- OJEU (BOE copy): Implementing Decision (EU) 2021/1339, harmonised standard EN 301 549 V3.2.1 for public sector websites and apps
- Ministry of Social Rights, Consumer Affairs and 2030 Agenda: Technical Support and Coordination Unit (UTAC) and how to file complaints
- Royal Board on Disability (Real Patronato sobre Discapacidad): Accessibility guide. Guidance for micro-enterprises (2024)
- Royal Board on Disability and Ministry of Social Rights: Accessibility in Consumer Affairs. Practical guide to guidelines and recommendations (2026)
- Judiciary (Poder Judicial): the National High Court upholds the €90,000 fine on Vueling over the accessibility of its website (22 March 2024)
- Federal Trade Commission: final order against accessiBe over its claims about WCAG compliance (April 2025)
- W3C: Web Content Accessibility Guidelines (WCAG) 2.2
- W3C WAI: WCAG overview (in Spanish)
- W3C WAI: Understanding WCAG 2.2 (explanation of each criterion)
- W3C WAI: Easy Checks, a first review of accessibility
- W3C WAI: Selecting Web Accessibility Evaluation Tools
- WebAIM: WAVE, accessibility evaluation tool
- WebAIM: WAVE, help and limitations
- Deque: axe DevTools extension (free and paid versions)
- Google: Lighthouse overview
- Google: Lighthouse accessibility scoring
- Google Lighthouse: text of the Accessibility category in the report (official source code)
- Google: About PageSpeed Insights
- W3C: Markup Validation Service, about the service