Normfluss
Free check

Spain

PDF accessibility in Spain

Transposition law
Ley 11/2023, de 8 de mayo (Título I)
In force since
2025-06-28
Supervising authority
Decentralised market-surveillance authorities designated by the autonomous communities, coordinated by a technical unit of the General State Administration
Official language(s)
es-ES

Enforcement

Breaches are sanctioned under applicable sectoral legislation and, subsidiarily, under Título III of the consolidated disability-rights law (Real Decreto Legislativo 1/2013). Infractions are classified as leves, graves, and muy graves, with fines from a floor of €301 up to €1,000,000 for the most serious; minor infractions do not exceed €30,000. Authorities may order corrective measures and withdraw non-compliant products.

What's specific to Spain

  • Spain applies EN 301 549, adopted nationally as UNE-EN 301549, incorporating WCAG 2.1 Level A and AA.
  • Public-sector web and app accessibility is governed separately by Real Decreto 1112/2018, which transposes the Web Accessibility Directive (2016/2102).
  • The Observatorio de Accesibilidad Web (OAW) monitors public-sector compliance and produces the triennial EU reports.
  • The sanctions regime builds on the pre-existing disability-rights framework (RDL 1/2013, Título III) rather than a new EAA-specific catalogue.
  • Market surveillance is regionalised across the autonomous communities and coordinated by a state-level technical unit; there is no single national enforcement agency.

What this means in practice

Spain's arrangement has two features an operator should plan around. The first is that market surveillance is decentralised: the autonomous communities designate their own authorities, coordinated by a state-level technical unit, so the body that scrutinises you can vary by region even though the underlying requirements are national. The second is that the sanctions regime is not a fresh EAA-specific catalogue: it leans on the pre-existing disability-rights law (RDL 1/2013), with infractions graded leve, grave and muy grave and fines reaching up to €1,000,000 for the most serious. The technical target is UNE-EN 301549, the Spanish adoption of EN 301 549 with WCAG 2.1 A and AA, so the same accessible-document work that satisfies the EU baseline satisfies Spain. Prioritise the high-volume, high-exposure documents (statements, invoices and consumer contracts) at the template level, and retain per-document evidence of what was checked.

What Normfluss does

Normfluss checks your PDFs against the technical criteria that underpin document accessibility. Tagging, reading order, alternate text, language, and structure. And issues a signed evidence record of exactly what was tested, in Spain and across the markets it serves. The evidence describes conformance within a stated scope; it is not a legal determination.

Languages. Checking and structural fixes work on documents in any language. Image descriptions are drafted in English, French, German and Dutch only, so a Spanish document whose images still need descriptions is refused rather than described in English, and nothing is charged.

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