New European Accessibility Law: when it enters into force and details for its enforcement

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.

The regulations focus on key areas such as:

1. Digital platforms: websites, mobile applications and other online services.
2. Financial and insurance documents: accessible in formats such as braille, labeled PDF and large print.
3. Interactive terminals: ATMs, payment terminals and similar devices.
4. Communication technologies: compatible with assistive tools such as screen readers and hearing aids.

• June 28, 2025: deadline to comply with the general accessibility requirements established in the directive.
• June 28, 2027: mandatory application of requirements related to accessibility in emergency communications (112) in some specific cases.

1. 1. Digital platforms
      Web sites and applications must comply with the principles of perceptibility, operability, comprehensibility and compatibility. They must conform to the standard EN 301 549, aligned with the WCAG 2.1 Level AA.
   2. Financial and insurance documents
      The availability of documents in accessible formats and in plain language must be ensured. This includes:
      1. Electronic documents compatible with screen readers according to ISO 14289-1 (PDF/UA).
      2. Specific requirements of the standard EN 301 549.
   3. Interactive terminals
      ATMs and payment terminals must be equipped with:
      1. Accessible voice and touch interface.
      2. Physical characteristics adjusted for persons with reduced mobility, according to ISO 9241-171 y EN 301 549.
   4. Communication technologies
      Solutions must include real-time text, audio and video synchronization, and support for tools such as teletext and assistive devices, according to the following standards EN 301 549 e ITU-T F.791.

Financial institutions and insurance companies must:

• 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 continuous assessment of compliance with requirements.

Failure to comply may result in administrative sanctions and operational restrictions, in addition to affecting the reputation of the organization.