Change is coming! Mandatory web accessibility by 2025: Are you ready?

📅 As of June 28, 2025, web accessibility ceases to be optional and becomes an unavoidable legal requirement in Spain. On that date, the sanctioning regime of accessibility regulations comes into force, which means that websites - both public and many private - may be fined if they do not comply with accessibility requirements.

This initiative is part of the European effort to ensure the digital inclusion of more than 100 million people with disabilities in the EU, marking a before and after in the digital landscape.

📖 In this article we explain which laws apply, what specific obligations you have as the person responsible for a website or e-commerce in Spain, what the penalties are for non-compliance, and how Inclusif can help you comply with the regulations.

🧭 Web accessibility regulations: from the public to the private sector

In Spain, web accessibility has been regulated for years, especially in the public sector. The pioneering Law 11/2007 already obliged public administrations to offer digital services accessible to citizens. This was followed by Royal Decree 1112/2018, which transposes Directive (EU) 2016/2102 📜 and establishes detailed accessibility requirements for all public sector websites and mobile apps.

According to this Royal Decree, all public bodies (ministries, city councils, universities, hospitals, etc.) must ensure that their portals are “perceivable, operable, understandable and robust” for any user, complying with the European standard UNE-EN 301549 (equivalent to the WCAG 2.1 level AA guidelines). In addition, it is required to publish and keep updated an Accessibility Statement detailing the level of compliance of the site, and to enable a communication channel for users to report barriers or request accessible information.

These obligations ensure that accessibility is integrated into the design, maintenance, and updates of public portals.

Until now, in the private sector, web accessibility did not have such a strict sanctioning mechanism, although there were standards and recommendations. However, this changes radically as of June 2025. Directive (EU) 2019/882, known as the European Accessibility Act (EAA), extends accessibility requirements to numerous private products and services across the European Union.

📌 Spain has transposed this directive through Law 11/2023, which establishes legal accessibility obligations for companies in various sectors and introduces a penalty regime for non-compliance. Specifically, from June 28, 2025, medium and large private companies will have to ensure that their websites and apps comply with accessibility standards just as the public sector does.

For the first time, European legislation imposes concrete requirements on the private sector in this area with real and significant penalties for non-compliance. The aim is to standardize digital accessibility across the EU and ensure that no one is excluded by web barriers.

🕵️‍♀️ Which websites must comply with accessibility laws?

All public sector websites (portals of state administrations, autonomous communities, local entities, public health services, education, justice, etc.) are obliged to be accessible, without exception. This includes electronic offices, information pages, online procedures and official mobile applications.

These entities should already have been WCAG 2.1 AA compliant for a few years now, given that the Royal Decree 1112/2018 deadlines for public websites and apps have already passed (2019-2020 for existing websites and 2021 for apps). If you manage a public portal, accessibility is not new to you, although it is advisable to periodically review the status of your website to ensure continued compliance and update the Accessibility Statement annually.

As for the private sector, the new accessibility law affects most medium and large companies that offer services to the public. In particular, they will be required to comply:

• E-commerce sites: Online stores of goods or services must be accessible to the public with disabilities. Even small businesses engaged in e-commerce fall under the scope: if you have less than 10 employees or turnover < €2 million but sell online, you are not exempt. The EAA considers e-commerce a “key sector” where even micro-enterprises must ensure accessibility.
• Banking and financial services: Online banking platforms, financial applications, ATMs with web interface, etc., must be usable by people with sensory or motor disabilities.
• ✈️ Transportation and tourism: Pages and apps for purchasing air, train, subway tickets; travel booking portals, hotels, etc., must meet accessibility requirements, facilitating for example booking by blind users or users with reduced mobility.
• 📡 Telecommunications: Websites of telephone and Internet operators, and customer service applications, have to be accessible.
• 🔌 Energy, water, and utilities sectors: Portals of electricity, gas, water, or other essential services companies are also included under the umbrella of mandatory accessibility (according to previous Spanish regulations).
• 🎓 Digital education and multimedia content: Private online education platforms, digital libraries, e-book services and players must ensure accessible content (e.g., e-books with screen reader compatibility).

In summary, sectors such as public administration, education, transportation, e-commerce, banking, telecommunications, among others, are clearly within the scope of the regulations.

Medium and large companies must be prepared to comply fully, while microcompanies are generally exempt only if they do not operate in these key sectors.

However, even if your company is not formally obliged, embracing accessibility brings competitive and reputational advantages: it broadens your potential customer base (there are more than 4 million people with disabilities in Spain) and improves the experience of all users. In fact, it has been observed that implementing accessibility guidelines can increase conversion rates by up to 15% in e-commerce by improving overall usability. In other words, what's good for accessibility is usually good for business.

📋 Key obligations: what does the law require of your website?

✅ 1. Comply with the technical standard WCAG 2.1 AA (or UNE-EN 301549) — The basis of the regulation is that your website should be perceptible, operable, understandable, and robust for everyone.

In practice, this means following the WCAG 2.1 AA guidelines, which cover numerous concrete measures: for example, providing alternative texts for images (so that blind users with screen readers understand the content), adding subtitles or transcripts to videos and multimedia for deaf people, ensuring adequate color contrast in text and buttons for those with low vision, and designing navigation that is usable with a keyboard (essential for people with reduced mobility who do not use a mouse).

It is also necessary to avoid content that could provoke convulsions (e.g., animations that flicker rapidly, thinking of users with photosensitive epilepsy) and to offer aids to focus attention (e.g., a highlight on the active element for those who navigate using a keyboard). In short, your site must be technically accessible: from the code (semantic HTML, ARIA tags where appropriate) to the visual design and texts, all conforming to international web accessibility standards.

📄 2. Accessible content and documentation — The obligation does not end with the web interface itself, but also encompasses the documents or information you provide. If you provide PDF files, downloadable forms, contracts, terms of service, product manuals, etc. on your site, these must also be accessible (e.g., PDFs correctly labeled for screen reading). Likewise, if you offer alternative content for certain users (such as “easy-to-read” versions for people with cognitive disabilities, or sign language for audiovisual content), you must keep it up to date. Accessibility should be integrated into all formats in which you distribute digital information.

🧾 3. Accessibility statement and feedback mechanisms (on public sites) — If you manage a government or public agency website, it is mandatory to include a public and updated Accessibility Statement.

In this document (usually linked in the footer of the portal), the degree of compliance of the site with the regulations, the non-accessible areas and why, and the communication options for citizens are reported. In addition, you must provide a way for any user to report accessibility problems or request content in accessible format. Typically, this is a contact form or a specific accessibility email address.

The entity is obliged to respond to these communications within a certain period of time. If the user does not get a response or is not satisfied, he or she can escalate a complaint to a supervisory body (in Spain, a monitoring body was designated at ministerial level to handle these complaints). This process ensures that there is effective enforcement in the public sector, even if there are no direct fines between administrations, the pressure to correct the reported barriers is high. In the case of private websites, the accessibility law does not explicitly require the publication of a similar statement (except perhaps in regulated sectors), but it is highly recommended for transparency. Some companies will opt for accessibility certifications or for displaying an accessibility seal.

🔄 4. Accessibility maintenance and upgrades - Compliance is not a one-time effort, but an ongoing commitment. Regulations (especially for the public sector) require periodic reviews and reporting on accessibility status.

No excuses can be made for “our website was compliant in 2020 but we haven't touched it since”; a constant effort to update is expected. Important: lack of technical knowledge, budget or priority are not considered valid reasons for non-compliance.

The law provides only very limited exceptions for disproportionate burden, but these must be justified and temporary. In other words, all organizations should plan and allocate resources for Web accessibility within their normal operations.

💣 Fines and risks of non-compliance

What happens if my website is not accessible from June 2025? A robust penalty regime will come into play in Spain. Companies or entities that fail to comply with accessibility obligations are exposed to significant financial penalties, the amount of which varies according to the seriousness of the infringement. Specifically, the law provides for fines of up to €90,000 for serious infringements, which can rise to up to €1,000,000 for very serious infringements.

These amounts place accessibility at the same level of importance as other mandatory regulations. For example, a commercial website with significant barriers on a large percentage of its pages could be fined tens of thousands of euros, and extreme cases of deliberate or repeated non-compliance could result in fines in the millions of euros.

But the consequences are not limited to the fine. The legislation provides for additional measures to force compliance. Authorities could, for example, suspend or revoke public subsidies and grants awarded to an organization that does not comply with accessibility.

Imagine a company that receives public funds or subsidies: failing to comply with accessibility standards could cost it the loss of that financial support. There is also a risk of exclusion from public tenders and contracts: entities that do not have their websites accessible may be disqualified from contracting with the Administration until the deficiencies are solved, since accessibility is an increasingly valued criterion in public procurement (and in many cases, a mandatory requirement in specifications). At the European level, the Accessibility Act even contemplates the possible prohibition of marketing non-accessible products or services.

This means that, for example, a mobile application or digital platform that is not adapted to users with disabilities could be withdrawn from the market until it is corrected. Similar (or harsher) sanctions will be seen in other EU countries, so multinational companies will have to comply in all markets to avoid facing legal problems.

Beyond the legal sanctions, not complying with accessibility entails reputational and market risks. A notorious case was the€90,000 fine imposed on the airline Vueling for having its website with 70% of accessibility requirements not complied with.

This type of news affects the public image: companies that do not address inclusion may be perceived as irresponsible or discriminatory. On the contrary, those that do comply can publicize it and improve their corporate social responsibility. In addition, an inaccessible website may face user complaints and lawsuits for discrimination under the General Disability Law. To date many organizations had treated accessibility as something voluntary without major consequences, but from now on non-compliance will have legal “teeth” and you will suffer the consequences if you do not act.

Summary:

😬 If your website is not accessible from June 2025:

• Fines of up to €90,000 (serious infringements) 💶
• Up to €1,000,000 in very serious cases 💥
• Risk of losing public subsidies 💔
• Possible exclusion from tenders ❌
• In the EU: ban on marketing non-accessible digital products.

👎 In addition to the economic:

• Legal risks (discrimination lawsuits) ⚖️
• Loss of reputation and public trust 🗞️
• Example: Vueling was fined 90,000 € for 70% of barriers on its website ✈️

The conclusion is clear: it is much more profitable to invest proactively in adapting your website than to risk fines, financial losses and brand damage later on.

🎯 Conclusions: Toward an inclusive, sanction-free website (act now!)

The entry into force of the new sanctioning regime on June 28, 2025, is a wake-up call for all web professionals and companies: accessibility is non-negotiable; it is now a legal obligation that carries with it severe fines and penalties for those who ignore it. But beyond avoiding sanctions, adopting accessibility is a commitment to quality, innovation, and social responsibility. It means offering a better user experience for everyone, expanding your market reach, and positioning your brand as a leader in inclusion.

The good news is that you still have time to get up to speed. Review your site, identify barriers (ideally with a professional audit), train your team in good accessibility practices, and take advantage of solutions that make things easier. Inclusif can be your greatest ally in implementing all the improvements you need to make your website accessible. Don't wait to receive a complaint or, worse, a fine: get ahead of it and take action today. Make your website compliant and provide an inclusive welcome to all your users.

🚀 Inclusif can help you:

• Audit your site
• Train your team
• Implement improvements
• Show your commitment

The next step? We invite you to try Inclusif on your own website and discover how easy it is to transform your site into an accessible space for everyone. 🎁

Start building a barrier-free website now – your audience will thank you, and so will your business. Don't let June 28, 2025, catch you off guard!