European Accessibility Act and its transposition
Accessibility has become a key element for companies, not only to comply with regulations, but also to gain a competitive advantage and be more valuable to society. The European Directive (EU) 2019/882 (known as the European Accessibility Act or EAA) and its transposition in Spain through Law 11/2023 seek to guarantee the inclusion of people with disabilities, among other things through real accessibility in everything related to essential products and services. And as it could not be otherwise, the standard establishes implementation deadlines until 2025 and 2027, depending on the sector.
In addition, Law 11/2023 imposes specific obligations on the financial and insurance sectors, as it requires all services, both digital and physical, to be fully accessible. This includes adapting websites, applications and documents to be usable by people with functional diversity. In addition, it specifically requires that communications, both graphical and digital, be equally understandable and accessible to all users.
For paper communications, these should be accessible through alternative formats, such as Braille or large print, and use a clear and legible design. For electronic communications, the Web Content Accessibility Guidelines (WCAG) 2.1 should be followed, ensuring that they are usable by all people, including those with disabilities.
Failure to comply with these obligations may result in penalties ranging from fines to suspension of activities. Infringements are classified as minor, serious and very serious, with penalties of up to one million euros.
In summary, Law 11/2023 seeks to promote inclusion and accessibility, benefiting both people with disabilities and businesses by opening up new market opportunities.
Summary with the main details
Scope of application
The regulations focus on key areas such as:
- Digital platforms: websites, mobile applications and other online services.
- Financial and insurance documents: accessible in formats such as braille, labeled PDF and large print.
- Interactive terminals: ATMs, payment terminals and similar devices.
- Communication technologies: compatible with assistive tools such as screen readers and hearing aids.
Important dates
| Date | Milestone | Status | Affects |
|---|---|---|---|
| June 28, 2025 | General Obligation to Comply with the EAA | Overdue — mandatory | All companies within the scope of application |
| June 28, 2027 | Accessibility Requirements for Emergency Communications (112) | Upcoming Deadline | Emergency Services and Specific Cases |
| June 28, 2030 | Exception for micro-enterprises with a proven disproportionate burden | Exemption Threshold | Micro-enterprises (subject to conditions) |
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Accessibility requirements
- Digital platforms. Web sites and applications must comply with the principles of perceivability, operability, comprehensibility and compatibility. They must conform to the standard EN 301 549aligned with WCAG 2.1 Level AA.
- Financial and insurance documents. The availability of documents in accessible formats and in clear language must be ensured. This includes:
- Electronic documents compatible with screen readers according to ISO 14289-1 (PDF/UA).
- Specific requirements of the standard EN 301 549.
- Interactive terminals. ATMs and payment terminals must be equipped with:
- Accessible voice and touch interface.
- Physical characteristics adjusted for persons with reduced mobility, according to ISO 9241-171 y EN 301 549.
- Communication technologies. Solutions must include real-time text, audio and video synchronization, and compatibility with tools such as teletext and assistive devices, in accordance with the standards EN 301 549 and ITU-T F.791.Humanize your brand’s digital communication by ensuring that every message reaches all users without barriers, understanding why designing accessible emails is both a legal obligation and an ethical commitment.
| Area | Applicable standard | Required Level |
|---|---|---|
| Digital platforms (web and apps) | EN 301 549 + WCAG 2.1 | Level AA |
| Electronic documents (PDF, email) | ISO 14289-1 (PDF/UA) + EN 301 549 | Screen reader compatible |
| Interactive terminals (ATMs, POS terminals) | ISO 9241-171 + EN 301 549 | Touch/voice interface + physical accessibility |
| Communication Technologies | EN 301 549 + ITU-T F.791 | Real-time text, accessibility support |
| Print Materials | Alternative formats (Braille, large print) | Plain language and legible design |
Implications for companies
Financial institutions and insurance companies must:
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- Audit and adapt your digital and physical services to meet applicable standards.
- Train their staff in inclusive care and in the use of accessible technologies.
- Ensure ongoing assessment of compliance with requirements.Overcome the limitations of your current platforms through custom technological solutions that automate even the most complex workflows, with specialized support from our Tech Agency.
| Type of violation | Description | Indicative maximum penalty |
|---|---|---|
| Minor | Formal or documentation non-compliance with no significant impact on accessibility | Up to €30,000 |
| Serious | Non-compliance with accessibility requirements with a real impact on users with disabilities | Up to €300,000 |
| Very serious | Repeated noncompliance or noncompliance that causes serious harm to people with disabilities | Up to €1,000,000 |
Failure to comply may result in administrative sanctions and operational restrictions, in addition to affecting the reputation of the organization.
Note: The final penalty regime in Spain depends on the implementing regulations for Law 11/2023. The figures provided are for guidance only, based on the framework of the Directive. Please consult legal counsel before publishing.
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Summary with the main details
Which companies are required to comply with the European Accessibility Act in Spain?
Companies with more than 10 employees or more than 2 million euros in revenue that provide digital products or services to consumers in the Spanish market are required to comply. The financial, insurance, and utilities sectors have additional specific obligations under Law 11/2023. Microenterprises may apply for an exemption by demonstrating a disproportionate burden.
What is the deadline for compliance with Directive (EU) 2019/882?
The general compliance deadline expired on June 28, 2025. Services and products launched before that date were granted a transition period. There is an additional deadline of June 28, 2027, for specific emergency communications requirements, and until 2030 for microenterprises that demonstrate a disproportionate burden.
What are the WCAG, and what level does the European Accessibility Act require?
The WCAG (Web Content Accessibility Guidelines) are the international web accessibility guidelines developed by the W3C. Directive (EU) 2019/882 requires compliance with the EN 301 549 standard, which is aligned with WCAG 2.1 Level AA. This level requires that digital content be perceivable, operable, understandable, and robust for users with any type of disability.
What penalties does Law 11/2023 provide for noncompliance with accessibility requirements?
Law 11/2023 classifies violations as minor, serious, and very serious. Penalties can reach up to one million euros in the most serious cases, in addition to the possibility of suspension of operations. Noncompliance also poses a reputational risk and may lead to complaints from consumers and associations of people with disabilities.
What specific obligations does the financial sector have under the Accessibility Act?
Financial institutions must ensure that all their digital services (website, app, online banking) comply with WCAG 2.1 AA, that financial documents (contracts, statements, terms and conditions) are available in accessible formats (PDF/UA, Braille, large print), and that electronic communications with customers are perceivable and understandable to people with visual, hearing, or cognitive disabilities.