Mandatory web accessibility: Law 11/2023 and who it affects

Since 28 June 2025, Spanish Law 11/2023 (which transposes the European Accessibility Act) requires certain digital products and services to be accessible to people with disabilities: among them, e-commerce services, consumer banking, e-books, passenger transport and electronic communications. Microenterprises providing services (fewer than 10 people and up to 2 million euros) are exempt, but accessibility is still the best decision you can make for a website that wants to sell to everyone. Here is the essential part and a checklist you can run through today.

What Law 11/2023 is and where it comes from

Law 11/2023, of 8 May is an "omnibus" law that transposes several European directives. Its Title I incorporates Directive (EU) 2019/882, known as the European Accessibility Act (EAA), on accessibility requirements for products and services. According to its eighteenth final provision, "Title I shall enter into force on 28 June 2025", the same date across the European Union. Unlike the previous rules (Royal Decree 1112/2018), which only bound the public sector, this one reaches private companies.

Who it affects

Article 2 lists the products (general-purpose computer equipment, self-service terminals such as ATMs or payment terminals, e-readers…) and the services provided to consumers it applies to. For a small business, the relevant ones are:

• E-commerce services (art. 2.2.f): any online shop or website where the consumer contracts and pays.
• Consumer banking services: online banking, apps.
• E-books and the software to read them.
• Electronic communications and access to audiovisual media services.
• Passenger transport: websites, apps, e-tickets, real-time information.

A corporate website that only informs (no online sales or contracting) is not covered by Title I. But beware: the moment you add paid bookings, a cart or online contracting, you become an e-commerce service.

The microenterprise exemption

Article 3.3 says it clearly: "microenterprises providing services shall be exempt from complying with the accessibility requirements". A microenterprise, in the Directive's sense, employs fewer than 10 people and has an annual turnover or balance sheet not exceeding 2 million euros. For those who manufacture or sell products, the exemption is not total: article 16.4 only relieves microenterprises from documenting the disproportionate-burden assessment. And the law provides general exceptions (art. 16) when compliance would impose a "disproportionate burden" or alter the basic nature of the product or service, always with justification.

What happens if you do not comply

Article 30 refers to the infringement and penalty regime of the relevant sector legislation and, on a subsidiary basis, to that of the General Law on the rights of persons with disabilities (Royal Legislative Decree 1/2013). Besides penalties, anyone can file complaints and reports (art. 29). In practice, the most immediate risk for an online shop is a complaint from a customer who cannot complete a purchase.

What "accessible" means on a website

The technical reference standard is the European norm EN 301 549, which for websites and apps points to WCAG 2.1 level AA (the Web Content Accessibility Guidelines; version 2.2 already exists and is the sensible target for a new project). These are concrete, testable criteria: sufficient colour contrast, full keyboard navigation, alternative text on images, labelled forms, subtitled videos, a correct heading structure and no flashing content.

A checklist you can run through today

1. Navigate with the keyboard only. Press Tab across the whole page: can you always see where you are (the focus)? Can you open the menu, close the cookie banner and submit the form without a mouse?
2. Contrast. Normal text with a minimum ratio of 4.5:1 against its background; large text 3:1. "Elegant" light grey on white is the most common failure.
3. Images with alt text. Informative ones with alternative text that describes; decorative ones with empty alt. No "image1.jpg".
4. One H1 per page and headings in order (H2, H3…), without skipping levels for aesthetic reasons.
5. Labelled forms. Each field with its label, errors explained in text (not just in red) and the faulty field identified.
6. Links and buttons that make sense out of context. "View product X", not "click here".
7. 200 % zoom without content being cut off or overlapping.
8. Videos with subtitles and no autoplay with sound.
9. Nothing flashing more than three times per second, and animations that honour the system's "reduce motion" preference.
10. The full purchase flow (cart, payment, confirmation) with the keyboard and with a screen reader (NVDA is free on Windows; VoiceOver is built into Mac and iPhone).
11. A published accessibility statement: what you comply with, what you do not yet, and a contact to report barriers.

Free tools for a first pass: Chrome's Lighthouse tab (Accessibility section), the WAVE extension and WebAIM's contrast checker. They do not replace a manual review, but they catch 30-40 % of the failures.

Why do it even if you are exempt

Millions of people in Spain have some disability, and add to that anyone browsing with the sun on the screen, with one hand busy or at 60 with presbyopia. An accessible website is easier for everyone, loads better, is better understood by Google and avoids complaints. At Cesko Design we design and build websites with these criteria from the first sketch, because fixing them afterwards costs more than doing it right the first time.

Frequently asked questions

My website is informational only, does Law 11/2023 apply to me?

If you do not sell or contract online and you are not in the listed sectors (banking, transport, telecoms, e-books), you are not covered by Title I. Even so, meeting the basic criteria is advisable.

I am self-employed with an online shop, do I have to comply?

If you are a microenterprise (fewer than 10 people and up to 2 million euros) and provide services, you are exempt under article 3.3. If you grow beyond those thresholds, you stop being exempt.

Is installing an "accessibility widget" enough?

No. Those overlays do not fix the code or the content, and user associations usually advise against them. Accessibility is achieved in design and development.

If you want to know whether your shop or website complies, tell us about your project and we will do a first review.