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Who the law covers, and since when
Law 11/2023 brings the European Accessibility Act, Directive 2019/882, into Spanish law. Title I, the part that deals with products and services, has been in force since 28 June 2025 (eighteenth final provision). Article 2.2 lists the consumer services it covers. Among others, these run through a website or an app.
The law defines e-commerce services as services provided at a distance through websites or mobile apps, by electronic means and at the individual request of a consumer, with a view to concluding a contract with that consumer (annex VII, definition 32). As examples, an online shop in Girona, a Costa Brava campsite with online booking or a clinic that takes paid appointments online would fit that definition. A site that only describes the business, on its face, does not.
- E-commerce services
- Consumer banking services
- Websites and apps of travel agencies and tour operators
- Websites, apps and e-tickets for passenger transport
- Websites and apps of electricity, water and gas suppliers
- Social networks
Are you a microenterprise? What the exemption means
Article 3.3 exempts microenterprises that provide services from the accessibility requirements for services and from any related obligation. The law defines a microenterprise as a business with fewer than 10 employees and an annual turnover or annual balance sheet total of no more than 2 million euros (annex VII, definition 16).
On those figures, that takes in many shops, restaurants, small clinics and holiday lets in Girona and la Selva. The exemption is for services, not for the products on the law's list, such as e-readers or payment terminals. And if you reach 10 employees, or exceed 2 million euros in both turnover and balance sheet total, you are no longer a microenterprise under that definition.
My website only has information and a contact form. Does the law apply to me?
On its face, no. The law defines e-commerce as a distance service aimed at concluding a contract with a consumer (annex VII, definition 32). If nothing is bought or contracted on the site, it does not fit that definition. If you add bookings or payments, that changes. When in doubt, ask a lawyer.
What a website or online shop has to comply with
Article 3.1 sends services to sections III and IV of annex I. Section III asks for information to reach people through more than one sensory channel, to be easy to understand, with an adequate font size and sufficient contrast, and for websites and apps to be perceivable, operable, understandable and robust.
For e-commerce, section IV adds that identification, security and payment functions must be accessible, and that the accessibility of the products on sale must be stated when the responsible operator provides that information. Article 13.2 asks service providers to explain in their general terms, or an equivalent document, how the service meets the requirements.
Which level? The third additional provision requires at least «the medium level of the generally recognised content accessibility criteria», with the Spanish standard UNE 139803 or its successor as the reference. In WCAG terms, that is read as level AA. EN 301 549 makes it concrete. Version 3.2.1 (2021) takes in WCAG 2.1 up to level AA, and version 4.1.1 (September 2026) moves to WCAG 2.2 and adds an annex for checking against Directive 2019/882.
We are 8 people with turnover under 2 million. Do we have to do anything?
If you provide services, article 3.3 exempts you from the requirements. Even so, everyone uses your website, and fixing contrast, text alternatives and forms is small work that serves more customers. If you sell products on the law's list, or grow past the figures in annex VII, look at it again.
Want us to look at your case? Leave us your details and we’ll tell you where we would start.
Let's talkHow to do a first check in an afternoon
You do not need special tools to find the most common problems. Take the home page, a product page and the form or the basket, and run these tests. Each one maps to a WCAG 2.1 success criterion.
| What to test | How | WCAG 2.1 criterion |
|---|---|---|
| Keyboard | Move through the page with Tab, no mouse. You should reach everything and see where you are. | 2.1.1 Keyboard (A) and 2.4.7 Focus Visible (AA) |
| Contrast | Text with a contrast ratio of at least 4.5 to 1 against its background (3 to 1 for large text), including over photos. | 1.4.3 Contrast (Minimum) (AA) |
| Images | Every image that carries information has a text alternative that says the same thing. | 1.1.1 Non-text Content (A) |
| Forms | Every field has a visible label or instruction. | 3.3.2 Labels or Instructions (A) |
| Zoom | Enlarge to 200 percent and check it still reads and works. | 1.4.4 Resize Text (AA) |
Do I need to meet WCAG 2.1 or WCAG 2.2?
The law names no version. Article 17 presumes compliance if you follow a harmonised standard whose reference is published in the Official Journal of the EU. EN 301 549 3.2.1 takes in WCAG 2.1 AA and version 4.1.1 WCAG 2.2 AA. As of October 2026, version 4.1.1 is not yet cited there and 3.2.1 remains the reference. Secure 2.1 AA, and aim for 2.2 AA in new work.
What can happen if you do not comply, and who checks
Title I sets no fine of its own. Article 30 refers to the infringement and penalty regime of the relevant sector legislation and, where that makes no provision, to Title III of the consolidated General Law on the rights of persons with disabilities (Royal Legislative Decree 1/2013). Article 30 contains no amounts.
Supervision falls to the authorities each autonomous community designates, Catalonia included (article 27.3). They must check that services comply, follow up complaints and verify that problems have been fixed (article 24). Article 29.2 lets consumers, associations and disability organisations go to the administrative bodies and the courts to demand compliance. There are exceptions, such as disproportionate burden, but they must be justified, assessed and documented, and the results kept for five years (article 16).
Does this guide replace advice from a lawyer?
No. Here we explain what the text of Law 11/2023 says in the BOE and what the technical standards say, with article numbers. If your case is borderline or you have received a complaint, talk to a lawyer. At crida studio we do the technical part and work to the legal advice you are given.
Fix the website or rebuild it. How to decide
If the site runs on WordPress with a well-built theme, most of the points in the table can be fixed without a rebuild. Contrast, text alternatives, form labels and keyboard focus. If the theme or page builder makes the menu unusable with a keyboard, or the basket and checkout cannot be corrected, a rebuild is usually the better investment.
At crida studio we look before we quote. We check the site with these tests, separate what can be fixed from what needs rebuilding, and put it in writing so you can compare proposals. We do not sell certificates. The law asks that the service be designed and provided in line with the requirements (article 13.1).
