Law 11/2023
The Spanish law that transposes the European directive on the accessibility of products and services. Here is what it says in broad terms and what we can measure on an online shop.
About the rule
- Type
- Spanish national law
- Date of the rule
- 8 May 2023
- Publication
- BOE no. 110, 9 May 2023
- Directive it transposes on accessibility
- Directive (EU) 2019/882, 17 April 2019
- Official source
- BOE-A-2023-11022, Law 11/2023
What it says, in broad terms
The full title of the law says it transposes European Union directives on the accessibility of certain products and services, along with other subjects unrelated to the web. The accessibility part answers Directive (EU) 2019/882.
That directive has applied since 28 June 2025 and covers, among others, e-commerce services. This means an online shop may have to offer its website in a way people with disabilities can use.
The four principles of web accessibility
WCAG, the technical reference we measure against, groups its criteria into four principles.
Perceivable
Visitors can perceive the information by sight, hearing or touch. For example, alternative text on product photos or enough contrast on buttons.
Operable
Everything can be used with a keyboard and without unfair time limits, and controls are big enough to press.
Understandable
Text reads well, the site behaves as expected and form errors say what happened and how to fix it.
Robust
The code is interpreted correctly by different browsers and by assistive technologies such as screen readers.
Services the directive includes
This is the list in Directive (EU) 2019/882 (article 2). The Spanish text may narrow it down.
E-commerce
Services contracted at a distance by electronic means, such as an online shop.
Consumer banking
Banking for consumers, including contracting through a website or app.
Passenger transport
Some elements of air, bus, rail and waterborne passenger transport services.
Electronic communications
Electronic communications services, including emergency calls.
Audiovisual media
Services giving access to audiovisual media.
E-books
E-books and the software used to read them.
What we measure
- Text contrast: at least 4.5:1 for normal text and 3:1 for large text (WCAG 2.2, criterion 1.4.3). Method: an automatic check in the browser. The report shows the measured value next to its threshold.
- Alternative text, form labels, keyboard use and page structure. Method: an automatic check in the browser, which covers only part of the WCAG 2.2 AA criteria.
What we don't measure
- Whether the law applies to your company or your shop.
- Whether your website is inside or outside what the law requires.
- Keyboard and screen reader tests by a person: we only do them in the diagnosis with human review.
- Any information or document the law asks your company for, if it asks for one.
Pending review by an adviser or lawyer
We could not confirm this against the official source, or it depends on your case. Don't take it as valid until someone has reviewed it.
- What exactly the Spanish text's list of services includes, and from when it applies to each one.
- Whether your company is out of scope as a microenterprise. The directive uses the definition in Recommendation 2003/361/EC (fewer than 10 people and an annual turnover or balance sheet of up to 2 million euros), but how it applies in Spain is for your adviser or lawyer to confirm.
- Transitional periods, the supervisory body and the penalty regime. We don't summarise them here.
Open the official source. Page written on 1 November 2026.
Other rules you may have heard of
Each one answers a different question. The pages complement each other.
RD 1112/2018
The Spanish royal decree on the accessibility of public sector websites and mobile apps. It is the rule most often mixed up with the ones for online shops.
See the page
WCAG
The W3C Web Content Accessibility Guidelines. They are not a law: they are the technical reference we measure against.
See the page
ADA
The Americans with Disabilities Act is a United States law. It only matters to you if you sell or provide a service there, and it is a subject for a lawyer.
See the page
EAA
The European Accessibility Act is Directive (EU) 2019/882. It is the European rule that affects people who sell online the most.
See the page
EN 301 549
The European standard for the accessibility requirements of ICT products and services. It is technical and voluntary on its own, but other rules take it as a reference.
See the page
Start by measuring your shop.
The automatic audit measures what can be measured from the outside and tells you what is left for your adviser or lawyer.