EAA enforcement in Spain: Ley 11/2023, regional authorities and fines

Which law applies

Ley 11/2023 is an omnibus law whose Title I transposes the accessibility directive, with e-commerce services in scope from 28 June 2025.

Do not confuse it with Real Decreto 193/2023, a broader decree on access to goods and services for people with disabilities, which requires public-facing websites to meet UNE-EN 301 549 on its own timetable (1 January 2029 for private goods and services).

The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025.

The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added.

Who enforces it for online shops

Article 27 of Ley 11/2023 gives market surveillance to the autonomous communities and the cities of Ceuta and Melilla, each designating its own authority. There is no single national e-commerce accessibility regulator.

Where conduct reaches beyond one autonomous community, as a national online shop usually does, the Directorate General for disability in the Ministry of Social Rights opens the sanction procedure, with a preliminary report from the Office for Disability Assistance (OADIS) (Ministry, RDL 1/2013, Article 105).

How a complaint reaches a shop

Complaints go to the regional consumer or disability authority, or to OADIS at national level. We did not find a single national online form for these complaints. Spanish disability law gives associations standing to act in defence of collective interests (RDL 1/2013).

Fines and other sanctions

Article 30 of Ley 11/2023 applies sector rules first and, where none apply, the sanction regime of the general disability law, Real Decreto Legislativo 1/2013. Under that regime (Articles 81, 83 and 96):

• Minor breaches: EUR 301 to EUR 30,000.
• Serious breaches, which include failing to meet accessibility requirements: EUR 30,001 to EUR 90,000.
• Very serious breaches: EUR 90,001 to EUR 1,000,000. Fines above EUR 300,000 need Council of Ministers approval.

Some online guides quote EUR 300,000 as the ceiling for serious breaches; in the statute that figure is a sign-off threshold, not a tier ceiling.

What has actually happened so far

We found no Spanish fine, sanction decision or lawsuit against a named online shop under Ley 11/2023 as of 1 October 2026. Regional enforcement makes early cases harder to spot, so absence of reports is not proof of absence of activity.

What to do if you sell into Spain

If you sell to consumers in Spain and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.

1. Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
2. Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
3. Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
4. Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
5. Re-test after every redesign, theme update or new app, and keep the reports.

A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.