REAL DECRETO 1112/2018 · FINES UP TO €1M

Accessibility audit for Spain — Real Decreto 1112/2018 & RD 193/2023

Check your website's compliance with Spanish accessibility law. Scrutia audits all WCAG 2.1 AA success criteria and delivers a Declaración de Accesibilidad-ready report.

€1M

max fine

82%

concordance rate

106

criteria tested

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Spanish accessibility framework

Spain has a two-pillar accessibility framework. Real Decreto 1112/2018 applies to public sector websites and mobile apps (effective September 2018), transposing EU Directive 2016/2102. Real Decreto 193/2023 extends similar requirements to private sector digital products and services, transposing the European Accessibility Act. Both reference WCAG 2.1 Level AA via the European standard EN 301 549.

Official reference: BOE — Real Decreto 1112/2018

Who must comply

  • Public administration — central, regional (Comunidades Autónomas) and local websites
  • E-commerce — all online retail targeting Spanish consumers
  • Banking and insurance — online banking, seguros, fintech
  • Transport booking — RENFE, ALSA, airline websites, ride-hailing
  • Telecommunications and digital media

Penalties in Spain

Spanish accessibility sanctions are graduated by severity and are among the highest in the EU:

  • Minor infringements: €301 to €30,000
  • Serious infringements: €30,001 to €90,000
  • Very serious infringements: up to €1,000,000
  • Temporary closure of the digital service and public disclosure of the decision

The Observatorio de Accesibilidad Web (OBA) conducts automated and manual audits of public sector websites and publishes the results twice a year.

How Scrutia helps with Spanish compliance

Scrutia audits your site against all WCAG 2.1 AA success criteria — the technical baseline referenced by Real Decreto 1112/2018 and Real Decreto 193/2023. The audit uses a real browser, tests dynamic interactions, and produces the evidence needed for your Declaración de Accesibilidad.

The full report (149 €) includes HTML/CSS/JS fix code for every issue, a management summary, and a remediation roadmap aligned with the UNE-EN 301 549 standard adopted by AENOR in Spain.

Learn more in our European Accessibility Act audit guide.

Check your Spanish compliance in 5 minutes

Scrutia audits WCAG 2.1 AA criteria referenced by Real Decreto 1112/2018 and delivers fix code for every issue.

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Spain accessibility law FAQ

What is Real Decreto 1112/2018?
Real Decreto 1112/2018 is the Spanish royal decree that transposes EU Directive 2016/2102 on the accessibility of public sector websites and mobile apps into Spanish law. It came into force in September 2018 and requires public sector websites and mobile applications to meet WCAG 2.1 Level AA. The Real Decreto 193/2023 later extended similar requirements to the private sector, transposing the European Accessibility Act.
Who enforces accessibility law in Spain?
The Observatorio de Accesibilidad Web (OBA), operated by the Ministerio para la Transformación Digital y de la Función Pública, is responsible for monitoring public sector website accessibility. For private sector compliance under the EAA (Real Decreto 193/2023), market surveillance authorities and consumer protection bodies at both national and regional (Autonomous Community) level share enforcement responsibilities.
What accessibility statement must Spanish websites publish?
Real Decreto 1112/2018 requires public sector sites to publish a Declaración de Accesibilidad (accessibility statement) using the template provided by the OBA. The statement must declare the conformance level, list any non-accessible content, provide a feedback mechanism, and be updated at least once a year. Private sector sites subject to Real Decreto 193/2023 must publish a similar statement.
What are the penalties for non-compliance in Spain?
Under the General Law for the Defense of Consumers and Users and the Ley General de Derechos de las Personas con Discapacidad, penalties range from €301 for minor infringements up to €1,000,000 for very serious infringements. Serious violations can also trigger the temporary closure of the service and reputational sanctions through the publication of the decision.
Does Spanish accessibility law apply to my company if I'm outside Spain?
Yes. If your website or digital service targets Spanish consumers — for example, if it is in Spanish, accepts euros, or ships to Spain — Spanish accessibility law applies regardless of where your company is established. This follows the market access principle of the European Accessibility Act and is confirmed by Real Decreto 193/2023.

Don't risk a €1,000,000 fine

Check your Spanish accessibility compliance in 5 minutes. Free audit, full report with fix code for 149 €.

Check Spanish compliance

No credit card required · Results in 5 minutes