REAL DECRETO 193/2023 · LIVE SINCE JUNE 2025

EAA compliance in Spain — Real Decreto 193/2023

Real Decreto 193/2023 transposes the European Accessibility Act into Spanish law. Enforcement has been live since June 28, 2025. Scrutia audits your site against UNE-EN 301 549 / WCAG 2.1 AA — the Spanish technical standard.

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2023

published in BOE

106

criteria tested

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Real Decreto 193/2023: Spain's EAA transposition

Published in the Boletín Oficial del Estado in March 2023, Real Decreto 193/2023 transposes the European Accessibility Act into Spanish law. It complements the public sector framework of Real Decreto 1112/2018 by extending accessibility obligations to private companies providing digital products and services to Spanish consumers.

The technical baseline is UNE-EN 301 549, the Spanish adoption of the harmonized European standard, which incorporates WCAG 2.1 Level AA for web content. AENOR publishes the UNE standard for use by Spanish companies.

Official reference: BOE — Real Decreto 193/2023

Covered products and services

  • E-commerce — tiendas online, marketplaces, servicios de suscripción
  • Banca y seguros — banca online, banca móvil, comparadores, fintech
  • Transport — RENFE, ALSA, Vueling, Iberia, ride-hailing
  • Telecommunications — Movistar, Orange, Vodafone, MasMovil customer portals
  • E-books and audiovisual — Casa del Libro, Filmin, Movistar Plus

Enforcement and sanctions

Spanish enforcement relies on the General Law for the Defense of Consumers and Users (Real Decreto Legislativo 1/2007), which provides the sanction framework for Real Decreto 193/2023:

  • 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 service and public disclosure of the decision

The Observatorio de Accesibilidad Web (OBA) supports enforcement with technical monitoring. Autonomous Communities also have regional enforcement powers.

How Scrutia helps

Scrutia automates the WCAG 2.1 AA assessment phase of Real Decreto 193/2023 compliance. The audit uses a real browser to test dynamic components, keyboard navigation, contrast, forms, and responsive behaviour — the areas most frequently cited in Spanish accessibility complaints.

The full report (149 €) includes HTML/CSS/JS fix code for every issue and is designed to support your Declaración de Accesibilidad aligned with the OBA template.

See also our country-specific Spain accessibility audit page and the wider EAA audit guide.

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Real Decreto 193/2023 FAQ

What is Real Decreto 193/2023?
Real Decreto 193/2023, published in the Boletín Oficial del Estado (BOE) in March 2023, is the Spanish royal decree that transposes the European Accessibility Act (Directive 2019/882) into Spanish law. It extends accessibility obligations to private sector digital products and services, complementing Real Decreto 1112/2018 which covers the public sector. The requirements entered into force on June 28, 2025.
How is RD 193/2023 different from RD 1112/2018?
Real Decreto 1112/2018 transposes EU Directive 2016/2102 and applies to public sector websites and mobile apps. Real Decreto 193/2023 transposes the European Accessibility Act (Directive 2019/882) and applies to private sector products and services. The two decrees share the same technical baseline — UNE-EN 301 549 (WCAG 2.1 AA) — but cover different types of organizations and use different enforcement mechanisms.
Which Spanish companies must comply with RD 193/2023?
Real Decreto 193/2023 covers private companies providing digital products and services to Spanish consumers, including e-commerce, banking, transport booking, e-books, telecoms, and consumer software. Micro-enterprises (fewer than 10 employees AND less than €2 million in annual turnover) are exempt from most obligations. Foreign companies serving Spanish consumers are also covered, following the market access principle of the EAA.
How does Spanish enforcement work under RD 193/2023?
Enforcement is shared between market surveillance authorities, consumer protection bodies at national level (Ministerio de Consumo) and regional level (Autonomous Communities), and sector-specific regulators. The General Law for the Defense of Consumers and Users provides the sanction framework, with fines ranging from €301 for minor infringements to €1,000,000 for very serious infringements. The Observatorio de Accesibilidad Web (OBA) supports technical monitoring.
What does a Spanish accessibility statement look like?
Companies subject to Real Decreto 193/2023 must publish a Declaración de Accesibilidad on their website. The OBA provides a standardized template in Spanish and in the co-official languages (Catalan, Galician, Basque). The statement must declare the conformance level, list non-accessible content, provide a feedback mechanism, and be updated annually. Scrutia audit reports produce the evidence needed to back up your Declaración.

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