It came into force on 28 June 2025, it is enforced by the CNMC, and the fines reach €600,000. Here is who it applies to and what it actually asks for.
Most business owners on this coast have never heard of it, and almost no web agency here mentions it. That is not a conspiracy — it is a piece of law that arrived quietly and applies to a lot of ordinary businesses.
What the law is
The European Accessibility Act is Directive 2019/882. Spain brought it into national law through Ley 11/2023 and Royal Decree 193/2023, and it took effect on 28 June 2025. The technical standard is EN 301 549, which in practice means conforming to WCAG 2.1 level AA.
Enforcement in Spain sits with the CNMC. Penalties reach €600,000 or 4% of turnover. Those are ceilings rather than opening offers, but they are not decorative.
Who it applies to
It covers e-commerce, banking and payment services, transport services, e-books, telephony and a handful of other digital services sold to consumers.
The exemption is the part worth reading twice. You are outside the scope only if you have fewer than 10 employees and under €2 million turnover — both conditions, not either. A twelve-person estate agency is in scope. A clinic group with three locations is in scope. A shop turning over €3M with four staff is in scope.
What it actually asks for
Nothing exotic, and nothing that requires a redesign. Four things account for most failures we find on audits:
- Keyboard access. Every control reachable with Tab, in a sensible order, with a visible focus ring. Custom dropdowns and modals are the usual offenders.
- Contrast. Body text at 4.5:1 against its background. Grey-on-white below
#767676fails. - Labels. Form fields need real
<label>elements. A placeholder is not a label — it disappears the moment someone types. - Information not carried by colour alone. A red border on an invalid field needs a message next to it.
Add captions on video, alt text that describes rather than names the file, and headings that follow a real hierarchy, and you have covered most of AA.
How to check in ten minutes
Press Tab through your homepage and watch where the focus goes. Try to complete your contact form without touching the mouse. Zoom the page to 200% and see whether anything overlaps. Open one product page and one checkout step in a screen reader — VoiceOver is already on your Mac.
If three of those four go badly, you are in the normal range for sites on this coast, and also outside what the law now requires.
What this is not
It is not a reason to rebuild your site. Most of what AA asks for is a set of corrections to markup and CSS, measured in days rather than weeks. The expensive version is the one where nobody looks until a complaint arrives.