Law 11/2023 (European Accessibility Act): a practical guide for websites and ecommerce
Version 0.1 — living draft. This guide summarises the regulation and replaces legal advice where it can: for your specific case, a lawyer. Updated with a date.
What it is
Law 11/2023, of 8 May (BOE-A-2023-11022) transposes Directive (EU) 2019/882 into Spanish law, known as the European Accessibility Act (EAA). It became fully applicable on 28 June 2025 and requires certain products and services to be accessible to people with disabilities. For the web channel, the reference standard is EN 301 549, which incorporates WCAG 2.1 AA (my practical recommendation: audit against WCAG 2.2 AA, which is stricter and gives you margin).
Who it affects
Operators providing these services in the EU, including non-European companies selling here:
- Ecommerce and distance selling
- Banking and payment services (home banking, card terminals, ATMs)
- Telecommunications
- Transport (websites, apps, machines and e-tickets)
- E-books and readers
- Self-service terminals, computers and operating systems
The public sector is not the EAA’s main addressee because it was already covered by RD 1112/2018 (WCAG 2.1 AA, mandatory audits and accessibility declarations), which remains in force in parallel.
Sanctions (Spain)
| Severity | Fine |
|---|---|
| Minor | Up to €30,000 |
| Serious | €30,001–90,000 (aggravated contexts: up to ~€300,000) |
| Very serious | Up to €1,000,000 |
And more important than the fine: reputation and demand. The 2025 Web Accessibility Barometer put non-compliance at around 98% of the Spanish private companies analysed, with disability organisations actively sending requests and filing complaints.
Where to start
- Baseline audit — a WCAG 2.2 AA barrier inventory with expert manual review (automated tools detect at most a third of the problems).
- Prioritised remediation plan — first whatever blocks key tasks (purchase, payment, contact), then the rest.
- Statement/documentation — for EAA services, accessibility information about the service; for the public sector, the RD 1112/2018 declaration.
- Maintenance — every release can break accessibility: integrate verification into CI (axe-core, pa11y) and re-audit at least every two years.
Common mistakes
- The miracle overlay. No “accessibility via one script” widget turns an inaccessible site into a conformant one: technical experts know it, and increasingly so do courts.
- Auditing with an automated tool only and calling it done.
- Confusing usable with accessible: they are different dimensions, and the regulation asks for the second one.
- Leaving it “until they fine us”: exposure started on 28 June 2025, with no moratorium.
Minimum checklist
- Do you sell/serve any of the affected services in the EU?
- Manual + automated WCAG 2.2 AA audit done within the last 24 months
- Critical barriers in the purchase/payment flow fixed
- People responsible for keeping accessibility identified
- Accessibility documentation available and findable
Guide by jquin.net — I’ve been auditing and fixing WCAG accessibility since 2009. If you need the audit or the plan, we do it at MaisMedia, and the court route lives in expert-witness work.