Mandatory web accessibility: what European law requires of your company
Mandatory web accessibility does not apply to every private website simply because it is publicly available. However, since 28 June 2025, it has applied to certain digital products and services offered to consumers. In Spain, Law 11/2023 implements the European Accessibility Act (EAA) in areas such as e-commerce, banking, transport, e-books and communications, with specific exemptions for microenterprises providing services.
In 2026, these obligations are already in force. Companies must determine whether they fall within the scope of the legislation and audit actual user journeys, including navigation, registration, identification and payment.
What is mandatory web accessibility and when did it take effect?
The EAA is Directive (EU) 2019/882, which establishes common requirements for certain products and services. The European Commission explains the scope of the European Accessibility Act, which covers computers, telephones, banking services, transport, e-books, communications and e-commerce.
Spain transposed the directive through Law 11/2023 on the accessibility of certain products and services. Title I of the law took effect on 28 June 2025. Since that date, operators within its scope have been required to design and provide services in accordance with the applicable requirements, retain information about compliance and correct any identified non-conformities.
This legislation should not be confused with the Web Accessibility Directive, which focuses on the public sector. A purely informational corporate website is not automatically covered by the EAA, although it may be covered when it forms part of a regulated service.
Which companies are subject to European accessibility legislation?
Mandatory web accessibility particularly affects companies that provide consumers with one of the services covered by the legislation. In the digital environment, one of the most relevant cases is e-commerce: services provided remotely through a website or application for the purpose of entering into a contract with a consumer.
Service or situation Could it be covered? Example B2C e-commerce Yes Online shop, booking or digital contracting Consumer banking services Yes Online banking, identification and payments Passenger transport Yes Information, tickets and transport applications E-books Yes E-books and specialised reading software Electronic communications Yes Telephone and digital communication services Informational corporate website Not necessarily Presentation of services without online contracting Exclusively B2B service Must be assessed separately Contractual portal aimed exclusively at businesses
Spanish legislation also covers certain digital elements relating to utilities, travel agencies, tour operators and social networks. The assessment must be based on the actual service provided.
The exemption for microenterprises
Microenterprises providing services are exempt from the requirements of Title I. The law defines a microenterprise as one that employs fewer than ten people and has an annual turnover not exceeding €2 million or an annual balance-sheet total not exceeding that amount.
The exemption does not mean that accessibility should be ignored: an inclusive interface improves usability and avoids the need for future rebuilding. Furthermore, the exemption applies only to microenterprises providing services; products are governed differently.
Other limitations and exceptions
The law excludes certain old content or content outside the company’s control, including some documents and multimedia content published before 28 June 2025, maps where the essential information is provided in an accessible format, third-party content that is neither funded nor controlled by the company, and website archives that have not been updated since that date.
A fundamental alteration or disproportionate burden may also be invoked in exceptional and duly justified circumstances. It is not enough to claim that adapting the website would be expensive: the situation must be assessed according to the legal criteria and proportionate improvements must still be implemented.
WCAG 2.2 and practical requirements for a business website
Mandatory web accessibility is often summarised by saying that a website must “comply with WCAG 2.2”. This is a useful technical objective, but it requires a legal qualification: the EAA establishes functional requirements and does not automatically turn every WCAG 2.2 criterion into a literal obligation for every company.
The W3C’s WCAG 2.2 guidelines organise accessibility around four principles: content must be perceivable, operable, understandable and robust. The W3C recommends using the latest version to anticipate future requirements.
In practice, a company should aim for a properly audited AA level as a minimum and review the following elements:
Keyboard navigation: menus, modal windows, forms and components must be usable without a mouse.
Visible focus: users must always be able to identify which element is currently selected.
Contrast and readability: text, buttons, statuses and messages must be clearly distinguishable.
Text alternatives: relevant images require descriptions, while audiovisual content requires captions or suitable alternatives.
Semantic structure: headings, lists, buttons and fields must be programmed in a way that screen readers can understand.
Accessible forms: labels, instructions, errors and confirmations must not rely solely on colour.
Zoom and reflow: content must remain usable when text is enlarged or viewed on small screens.
Accessible authentication: access must not depend exclusively on cognitive tests that are difficult to complete.
Sufficient time: sessions, warnings and time-limited operations must accommodate users’ needs.
For e-commerce services, the law pays particular attention to identification, security and payment functions. An accessible homepage is of little value if the user is blocked when registering, accepting terms or completing a purchase.
In our projects, we find issues that are invisible during a visual review, such as cookie banners that trap keyboard focus and forms without labels that screen readers can interpret. Both can prevent users from completing an essential action even when the design appears correct.
What penalties can be imposed for non-compliance?
There is no single automatic fine for breaching mandatory web accessibility requirements. Law 11/2023 states that infringements are penalised under the relevant sector-specific legislation. Where this legislation does not cover the situation, the general system governing the rights of people with disabilities applies on a supplementary basis.
Classification under the general system Maximum applicable range Minor infringement From €301 to €30,000 Serious infringement From €30,001 to €90,000 Very serious infringement From €90,001 to €1,000,000
These figures do not mean that every error will result in the maximum penalty. Classification depends on the sector, severity, intent, people affected, repeated infringements and previous enforcement notices. The company may also be required to correct the service.
The most likely risk is not solely financial. An inaccessible website may prevent users from purchasing, booking, paying or requesting assistance, damaging both reputation and conversion. Accessibility should be treated as a product quality requirement rather than as a last-minute legal correction.
How to audit and adapt a website without rebuilding it blindly
A mandatory web accessibility audit must combine automated tools with manual reviews. Scanners help identify repeated errors, but they cannot determine on their own whether a process is understandable, whether the focus order makes sense or whether a description communicates the correct information.
Determine the legal scope: identify the services, users, markets, company size and possible exceptions.
Select critical user journeys: navigation, search, registration, purchasing, payment, contact and account management.
Run technical tests: semantic HTML, contrast, accessible names, statuses, errors and compatibility.
Test without a mouse and with assistive technology: use a keyboard and screen readers across a representative sample.
Prioritise by impact: first correct barriers that prevent users from completing essential tasks.
Document and maintain: record decisions, provide compliance information and incorporate accessibility into the publishing process.
It is not always necessary to rebuild the entire website. Many barriers can be corrected by adjusting components, styles, forms and content. If the underlying architecture creates errors across every page, renewing the technical foundation may be more efficient.
Mandatory web accessibility must also be incorporated into maintenance: every banner, plugin or form can introduce new barriers. At Owius, we integrate accessibility testing into design, development and quality assurance.
You can learn more about the principles of inclusive design in our article on the importance of accessibility in web design.
Frequently asked questions
Are all companies required to have an accessible website?
No. The EAA does not automatically turn every privately owned website into a regulated service. It applies to specific products and services, including B2C e-commerce, banking, transport and communications. There is also an exemption for microenterprises providing services, although other sector-specific rules may still apply.
When did mandatory web accessibility take effect?
Effective application began on 28 June 2025. In Spain, this date corresponds to the entry into force of Title I of Law 11/2023. Transitional measures exist for certain contracts and products, but any new online shop or digital service must now assess its compliance.
Is WCAG 2.2 AA compliance mandatory?
The EAA does not formulate it universally in those terms. The law establishes functional requirements and may rely on harmonised standards. Nevertheless, WCAG 2.2 AA is a recommended technical objective because it incorporates the earlier criteria and improves areas such as focus, authentication and touch controls.
Does an accessibility plugin make a website compliant?
No. A widget cannot correct the underlying code, structure, keyboard navigation, forms or purchasing process by itself. Some tools allow users to adjust the presentation, but they do not replace an audit or the correction of underlying barriers. Compliance requires accessible design, content and development.
How much does it cost to make a website accessible?
It depends on the website’s size and technology and on the severity of its problems. A website with well-developed components may be corrected through an audit and limited improvements, while a platform with structural errors will require more extensive work. The budget should separate diagnosis, correction, manual testing, documentation and ongoing monitoring.
Mandatory web accessibility requires a precise assessment of the service, without assuming that every company has the same obligations or relying on automated solutions. Acting now reduces legal risk, improves the user experience and prevents barriers from accumulating in future updates.
Owius is a software, application and artificial intelligence development company in Barcelona with more than 25 years of experience. If you need to audit, adapt or redesign your website, discover our professional web design service in Barcelona and approach the project from an accessible, maintainable foundation designed for growth.