Accessibility law · Europe

Spain EN 301 549 V3.2.1 → WCAG 2.1 AA

In Spain, the standard to meet is EN 301 549 V3.2.1 → WCAG 2.1 AA. It binds public-sector bodies, and since June 2025 private providers of e-commerce, consumer banking, telecoms, transport, e-books, utilities, travel and social networks (service microenterprises excepted). This page was reviewed against primary sources on 30 September 2026.

Standard
EN 301 549 V3.2.1 → WCAG 2.1 AA
Private sector
Partly
Accessibility statement
Required
Next deadline
28 Jun 2030
Reviewed
30 September 2026
The 50 criteria All jurisdictions Checklist

Scope

Who it applies to

Public-sector websites and apps must meet the harmonized standard EN 301 549 (WCAG 2.1 AA), publish an accessibility statement reviewed at least once a year, and answer accessibility complaints (Real Decreto 1112/2018). Since 28 June 2025, Ley 11/2023 applies the European Accessibility Act to private services sold to consumers, and Spain added utility, travel agency and social network sites and apps to the EU list. Breaches of Ley 11/2023 are fined under sector law or, where that is silent, under the national disability law, whose fines run from €301 to €1,000,000.

  • Public sector

    State, regional and local administrations, the institutional public sector, associations of public bodies and the courts (RD 1112/2018 art. 2). Constitutional and oversight bodies such as the Cortes, Constitutional Court, Court of Audit, Ombudsman and Banco de España apply the same criteria, and administrations must require them of publicly funded sites and of contractors that run public services.

  • Private sector

    Partly

    Since 28 June 2025, providers of these consumer services: electronic communications, access to audiovisual media, air, bus, rail and water transport (websites, apps, e-tickets, travel information, terminals), consumer banking, e-books, e-commerce, and (a Spanish addition) the websites and apps of electricity, water and gas suppliers, travel agencies and tour operators, and social networks. Microenterprises that provide services (fewer than 10 staff and turnover or balance sheet of €2 million or less) are exempt.

Coverage

What it covers

Websites are only part of it. Each tile says whether these rules reach that kind of product, with the detail.

  • Websites

    Covered

    All public-sector sites; private sites in the Ley 11/2023 sectors.

  • Mobile apps

    Covered

    Public-sector apps since 23 June 2021; private apps in the covered sectors.

  • Documents

    Covered

    Downloadable documents and forms count; older office files are exempt.

  • Software

    Partly

    Consumer computers and their operating systems, and e-book software only.

  • Kiosks and terminals

    Covered

    Payment terminals, ATMs, ticket and check-in machines, info kiosks and queue-ticket machines.

  • Public procurement

    Covered

    Ley 11/2023 art. 25 makes its requirements mandatory in public contracts for covered products and services.

Timeline

Deadlines

Next: 28 Jun 2030. Transition ends for services still delivered with older products; pre-2025 service contracts may run no longer than five years from 28 June 2025.

Dates move, so check the linked source before you plan around one.

  1. 20 Sep 2018 In force

    Real Decreto 1112/2018 takes effect for public-sector websites.

    Source

  2. 20 Sep 2019 In force

    The complaints and claims procedure applies to public-sector websites launched after the decree.

    Source

  3. 20 Sep 2020 In force

    The claims procedure also applies to older public-sector websites; each website's first accessibility review is due.

    Source

  4. 23 Jun 2021 In force

    All provisions apply to public-sector mobile apps.

    Source

  5. 10 May 2023 In force

    Ley 11/2023 takes effect and repeals the old web accessibility provision of the LSSI (Ley 34/2002).

    Source

  6. 28 Jun 2025 In force

    Title I of Ley 11/2023 (the European Accessibility Act) applies to covered products and consumer services.

    Source

  7. 28 Feb 2026 In force

    Real Decreto 143/2026 takes effect: the national coordination unit for surveillance authorities is set up.

    Source

  8. 28 Jun 2030 Upcoming

    Transition ends for services still delivered with older products; pre-2025 service contracts may run no longer than five years from 28 June 2025.

    Source

Instruments

The law in Spain

5 laws, rules and rulings, oldest first. Each links to its primary source.

Every fact points at a primary source. Dates move, and several moved in 2025 and 2026, so check the source before you rely on one.

  1. 2002

    Ley 34/2002 (LSSI), disposición adicional quinta

    Law on information society services; the provision is now repealed

    Carried Spain's older duty of web accessibility for people with disabilities and older people. Repealed by Ley 11/2023, whose preamble says its content moved into art. 2.2 g) to i): utility, travel agency and social network services.

    Primary source

  2. 2013

    Real Decreto Legislativo 1/2013, título III

    General law on the rights of persons with disabilities: offenses and sanctions

    The fallback sanctions regime for Ley 11/2023. Fines run from €301 to €1,000,000; failing accessibility requirements is a serious infringement (up to €90,000), minor infringements up to €30,000. Regions set out the detailed offenses.

    Primary source

  3. Sep 2018

    Real Decreto 1112/2018

    Accessibility of public-sector websites and mobile apps; transposes Directive (EU) 2016/2102

    Public-sector websites and apps must be perceivable, operable, understandable and robust, presumed met by the EU harmonized standard (EN 301 549). Requires a yearly accessibility statement, a feedback and complaints channel, a claims procedure, periodic reviews and a designated accessibility unit.

    Primary source

  4. May 2023 (applies Jun 2025) Latest

    Ley 11/2023, título I

    Transposes the European Accessibility Act, Directive (EU) 2019/882

    Accessibility requirements for consumer products and services from 28 June 2025, including e-commerce, banking, telecoms, transport, e-books and, beyond the directive, utility, travel agency and social network sites and apps. Covered websites must also meet at least the middle level of recognized content criteria (additional provision 3).

    Primary source

  5. Feb 2026

    Real Decreto 143/2026

    Creates the technical support and coordination unit for accessibility surveillance authorities

    Makes the Dirección General de Derechos de las Personas con Discapacidad the national unit that supports and coordinates the regional surveillance authorities for Ley 11/2023, collects data on sanctions and gives the public a channel for complaints.

    Primary source

Enforcement

Enforcement and penalties

  • Who enforces

    Public sector: each body's designated accessibility unit (Unidad responsable de accesibilidad) handles claims, and RD 1112/2018 art. 18 makes the ministry for public administration (then the Ministerio de Política Territorial y Función Pública) the monitoring and reporting body. Private sector: surveillance authorities named by each autonomous community and by Ceuta and Melilla, coordinated since February 2026 by the Dirección General de Derechos de las Personas con Discapacidad, which also acts as the authority where none has been named.

  • How

    Public sector: users send a complaint or request to the body, which must answer within 20 working days; a refusal can be taken to the accessibility unit, which has two months, and then to an administrative appeal. The ministry samples sites and reports to the European Commission every three years. Private sector: authorities check conformity, follow up complaints and verify corrective action (Ley 11/2023 art. 24 and 29).

  • Penalties

    RD 1112/2018 sets no fines for public bodies. Ley 11/2023 art. 30 applies the sanctions in the relevant sector law and, where that is silent, Title III of Real Decreto Legislativo 1/2013: fines from €301 to €1,000,000, with failing accessibility requirements listed as a serious infringement capped at €90,000 and minor ones at €30,000. Regions set out the detailed offenses.

  • Individuals

    Anyone can complain to a public body and then claim and appeal. For Ley 11/2023, consumers, public bodies, disability organizations and other legal persons with a legitimate interest can go to the administrative bodies and the courts, and the disability arbitration system and consumer procedures are also available (art. 29).

Accessibility statement

A statement is required

Required

Public bodies must publish a detailed accessibility statement for each website and app, linked from every page as "Accesibilidad", and update it at least once a year or after each accessibility review. It must list inaccessible content with reasons and alternatives, and link to the feedback channel and the claims procedure (RD 1112/2018 art. 15). Private service providers must put information on how the service meets the requirements in their general terms or an equivalent document, in accessible form, and keep it current while the service runs (Ley 11/2023 art. 13).

Exemptions

What is exempt

Exemptions are narrow and usually have to be claimed and explained, not assumed.

  • Disproportionate burden, assessed in writing: yearly review for public bodies, every five years for service providers; lack of time, priority or knowledge is not a valid reason (RD 1112/2018 art. 7).
  • Changes that would fundamentally alter a product or service (Ley 11/2023 art. 16).
  • Service providers that received outside funding to improve accessibility cannot claim disproportionate burden.
  • Microenterprises that provide services (Ley 11/2023 art. 3.3).
  • Office files and prerecorded video or audio published before the rules applied (20 September 2018 for public bodies, 28 June 2025 under Ley 11/2023), unless public-sector files are needed for active administrative tasks.
  • Live time-based media on public-sector sites.
  • Online maps, if essential information is given accessibly for navigation maps.
  • Third-party content that is not funded, developed or controlled by the organization.
  • Archived content not updated after the rules applied.
  • Reproductions of heritage collection items that cannot be made accessible (public sector).
  • Public-sector extranets and intranets published before 23 September 2019, until substantially revised.
  • Live and prerecorded media of public service broadcasters, which have their own rules.
  • Self-service terminals in use before 28 June 2025 may stay in service until the end of their economic life, but no more than 10 years after entry into use.

The standard

What WCAG 2.1 Level AA asks for

50 success criteria: 30 at Level A and 20 at Level AA. 4.1.1 Parsing counts in this version, but WCAG 2.2 removed it as obsolete, so it has no page here.

1. Perceivable

2. Operable

3. Understandable

4. Robust

Beyond the law

6 Level A and AA criteria in WCAG 2.2 that these rules do not require yet. Meeting them now costs little and is where the rules are heading.

Meeting it

Where to start

The standard named here is WCAG 2.1 Level AA.

  1. Audit your pages against WCAG 2.1 Level AA: 50 success criteria at Level A and AA.
  2. Check text and control contrast in the Contrast Checker.
  3. Run the URL Analyzer for the problems a machine can find, then test with a keyboard and a screen reader.
  4. Publish an accessibility statement that says what does not meet the standard yet, and how to report a problem.
  5. If you sell to the public sector, document conformance in an accessibility conformance report, such as a VPAT or an EN 301 549 statement.
  6. Work through the Accessibility Checklist and keep a record of what you tested.

This is a summary to orient you, not legal advice. For a decision that matters, read the primary sources and ask a lawyer who practices there.

Questions

Common questions

  • Does it apply to private companies?

    Yes, since 28 June 2025, if you provide a covered service to consumers: e-commerce, consumer banking, electronic communications, access to audiovisual media, passenger transport, e-books, and in Spain also the websites and apps of electricity, water and gas suppliers, travel agencies, tour operators and social networks. Service microenterprises (fewer than 10 staff and €2 million or less in turnover or balance sheet) are exempt.

  • Which WCAG level do I need?

    Public bodies are presumed compliant if they meet the EU harmonized standard, EN 301 549 V3.2.1, which draws on WCAG 2.1; aim for WCAG 2.1 AA. Ley 11/2023 asks covered websites for at least the middle level of recognized content criteria and names UNE 139803, or the standard that replaces it, as the reference.

  • Do private companies need an accessibility statement?

    Not the public-sector model statement. But service providers under Ley 11/2023 must describe, in their general terms or an equivalent document, how the service meets the accessibility requirements, in accessible written and oral form, and keep that information current while the service runs.

  • What are the fines?

    Ley 11/2023 uses the sanctions of the relevant sector law first. Where that law is silent, the disability law applies: fines from €301 to €1,000,000, with failing accessibility requirements treated as a serious infringement capped at €90,000. Public bodies face no fines under RD 1112/2018.

  • Who do I complain to about an inaccessible private site?

    The surveillance authority of the autonomous community concerned. The Dirección General de Derechos de las Personas con Discapacidad coordinates those authorities, runs a national contact point for complaints and acts as the authority where a region has not named one. You can also go to court or use the disability arbitration system.

Sources

Sources

Every fact on this page comes from one of these; the few secondary sources are marked. Reviewed 30 September 2026.

Elsewhere

Also in Europe

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