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European Accessibility Act: Spain (Ley 11/2023)
ES- Applies from
- 2025-06-28
- Maximum penalty
- €1,000,000
- Enforcement authority
- Sector-specific market surveillance authorities, coordinated since February 2026 by the UTAC (Unidad Técnica de Apoyo y Coordinación), created under Real Decreto 143/2026 and attached to the Dirección General de Derechos de las Personas con Discapacidad — https://www.boe.es/buscar/act.php?id=BOE-A-2026-4520
- Microenterprise exemption
- Yes — under the EAA's EU-wide microenterprise exemption for services
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- National law
- Ley 11/2023, de 8 de mayo, Título I
- Notes
- Ley 11/2023 (art. 30) sends breaches first to the sanctions regime of each sector's own legislation. Where that legislation provides nothing, Title III of the General Disability Law (Real Decreto Legislativo 1/2013) applies as a fallback: fines from €301 to €1,000,000, with minor infractions capped at €30,000 and serious ones at €90,000, so very serious infractions run up to €1,000,000 (art. 83). The amount is graded by intent, negligence, ignored prior warnings, turnover, number of people affected, recurrence and economic benefit obtained (art. 84).
Who is obligated in Spain
The law covers a broad list of consumer-facing digital products and services: e-commerce and marketplaces, banking and insurance, passenger transport apps and e-ticketing, self-service terminals such as ATMs and ticket machines, and consumer electronics like smartphones and tablets. The microenterprise exemption is the standard EU-wide one — fewer than 10 employees and annual turnover or balance sheet total of €2 million or less — and for those businesses it's a full exemption from the obligation, not just a lighter version of it.
What happens if you don't comply
Ley 11/2023 does not create its own fines. Article 30 applies the sanctions regime of each sector's legislation first and, where that says nothing, falls back on the General Disability Law (Real Decreto Legislativo 1/2013), which classifies infractions as minor, serious or very serious and fines them from €301 up to €1,000,000. Within that range the amount depends on intent, how many people were affected, the company's turnover, whether it had been sanctioned before and any economic benefit it gained. The sector-specific surveillance authorities handle individual cases, now coordinated by the UTAC created in February 2026 specifically to keep their interpretation and enforcement consistent across sectors.
How this differs from the EU baseline
Spain's fallback ceiling of €1,000,000 for very serious infractions is one of the highest fixed figures in any national transposition, although it applies only where a sector's own legislation does not set the penalty. The other distinctive feature is procedural rather than substantive: rather than a single national regulator, Spain kept enforcement sector by sector and only added a coordinating body (the UTAC) in 2026, after the obligations had already come into force, specifically to smooth out inconsistent enforcement across those sectors.
How to complain
Start with the business itself — contact the company directly about the accessibility problem first. If that doesn't resolve it, the law requires the relevant sector authority to act as a point of contact for the public and to provide a way to submit complaints about non-compliance. In parallel, general consumer complaints can go through your local OMIC (Oficina Municipal de Información al Consumidor).
Frequently asked questions about the EAA in Spain
- What is the maximum EAA fine in Spain?
- The maximum penalty is €1,000,000. Ley 11/2023 (art.
- Who enforces the European Accessibility Act in Spain?
- Sector-specific market surveillance authorities, coordinated since February 2026 by the UTAC (Unidad Técnica de Apoyo y Coordinación), created under Real Decreto 143/2026 and attached to the Dirección General de Derechos de las Personas con Discapacidad. Details are published at https://www.boe.es/buscar/act.php?id=BOE-A-2026-4520.
- Since when does the EAA apply in Spain?
- The requirements apply from 28 June 2025, the EU-wide date, transposed into Spain by Ley 11/2023, de 8 de mayo, Título I.
- Are small businesses exempt from the EAA in Spain?
- Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Spain that places a covered product on the market still has to make that product accessible.
Official source: https://www.boe.es/buscar/act.php?id=BOE-A-2023-11022
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.