Scope diagnosis
We analyse whether your activity and your channels —website, app, customer service, contracts, e-invoicing— fall within the scope of Law 11/2023.
Cumplimiento
Accessibility Law (EAA)
The EAA accessibility law —Directive (EU) 2019/882 and its Spanish transposition, Law 11/2023— has required since 28 June 2025 that e-commerce, banking, passenger transport, e-books and electronic communications be accessible to people with disabilities. We help you diagnose the gap and build the compliance plan before an inspection arrives.
Law 11/2023, of 8 May, transposes Directive (EU) 2019/882 —the European Accessibility Act— into Spanish law. It requires manufacturers, importers, distributors and service providers operating in Spain to make certain products and services accessible: computers and operating systems, self-service terminals (ATMs, ticket machines, check-in points), telecommunications and audiovisual equipment, electronic communications services, consumer banking, e-commerce, e-books and passenger transport. The specific technical requirements are set out in the annexes to the law.
The obligations apply from 28 June 2025 to products and services placed on the market from that date. There are transitional periods: service providers may keep using, until 28 June 2030, products they were already using lawfully before 2025; self-service terminals already in use may continue until the end of their economic useful life, but no longer than twenty years after they were put into service; and emergency communications to 112 have an extension until 28 June 2027.
Royal Decree 193/2023, of 21 March, regulates, more broadly, the basic conditions of accessibility and non-discrimination in the access to and use of goods and services available to the public. It is not a hierarchical development of Law 11/2023, but it overlaps with it in areas such as banking, websites or self-service, so it is worth reviewing both together.
We help SMEs and service providers position themselves against this regulation with a practical approach. We identify whether your activity and your channels —website, app, customer service, contracts, e-invoicing— fall within its scope, we assess the gap against the requirements of the annexes and we document the compliance plan, including the disproportionate burden assessment where relevant. We don't work with generic checklists: we tailor the analysis to your sector and your real channels.
Non-compliance has consequences. Chapter XI of the law (articles 27 to 31) covers the surveillance authorities, the control mechanisms and the penalty regime, which for matters not expressly provided refers to the general legislation on the rights of persons with disabilities; fines are graded according to severity and, in the most serious cases, reach very high amounts. Added to this are reputational risk and possible exclusion from grants or public procurement. We also support you in responding to requirements, to reduce risk without promising outcomes that don't depend on documentation alone.
The Accessibility Law (EAA) process.
The process · four stagesGap assessment
We check your products and services against the technical requirements in the law's annexes to identify what still needs adapting.
Documented compliance plan
We build the prioritised compliance plan with you, including the disproportionate burden assessment where relevant.
Support before requirements
We support you in responding to inspections or requirements from the surveillance authorities, with the documentation already in place.
What is included
What Accessibility Law (EAA) includes.
The operational detail: what we deliver as part of the work and what we keep alive afterwards.
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Scope diagnosis
Determination of which products, services and channels of your activity fall within Law 11/2023.
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Annex-by-annex gap assessment
Comparison of your current situation against the technical accessibility requirements of each applicable annex.
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Prioritised compliance plan
A document with the necessary actions, ranked by urgency and by channel.
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Disproportionate burden assessment
Documented analysis of the cases where the law allows justified exceptions.
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Cross-check with Royal Decree 193/2023
Review of overlaps with the basic accessibility conditions for goods and services.
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Support responding to requirements
One-off support if an inspection or a request arrives from a surveillance authority.
Summum cluster
How it connects with its sisters.
Frequently asked questions about Accessibility Law (EAA).
Which companies does the EAA accessibility law apply to?
Those that manufacture, import, distribute or provide the products and services covered by Law 11/2023: e-commerce, consumer banking, electronic communications, passenger transport, e-books, self-service terminals and audiovisual or telecommunications equipment. It applies regardless of company size, except for the exemptions for microenterprises set out in the law itself.
From when is compliance mandatory?
From 28 June 2025 for products and services placed on the market from that date. There are transitional periods: service providers may keep using products already used before 2025 until 28 June 2030, self-service terminals in use may run out their economic useful life (capped at twenty years from entry into service) and communications to 112 have an extension until 28 June 2027.
What is the difference between Law 11/2023 and Royal Decree 193/2023?
Law 11/2023 transposes Directive (EU) 2019/882 and regulates the accessibility of specific products and services. RD 193/2023 regulates, more generally, the basic conditions of accessibility and non-discrimination in goods and services available to the public. There is no hierarchical relationship between them, but they complement each other and are best reviewed together.
What happens if my company doesn't comply?
The law provides for a penalty regime (Chapter XI) with fines graded according to the severity of the infringement that, in the most serious cases, can reach very high amounts. Beyond the financial penalty, there is reputational risk and the risk of exclusion from grants or public procurement.
How do we start adapting?
With a diagnosis of which products, services and channels of your activity fall within the scope of the law, checked against the technical requirements of the annexes. From there we build the prioritised compliance plan with you, without promising a level of compliance that depends on factors beyond our control.