Spain's EAA Enforcement: Sectoral Penalties and Regional Authorities
Spain has no single accessibility fine and no single accessibility regulator. What you'd pay depends on your sector and which of 19 regional authorities you fall under — with the general disability law (up to €1,000,000) only as a fallback.
Quick answer
Spain's EAA law (Ley 11/2023) sets no fine amount of its own. Instead, a breach is punished under whatever sector law already governs it — banking law for a bank, telecoms law for a telco, e-commerce law for an online shop — and only where that sector law is silent does the general disability law (RDL 1/2013), with fines up to €1,000,000, apply as a fallback. Enforcement is handled by up to 19 regional authorities, not a national regulator. There is no single "Spain EAA fine" to quote.
Why there's no single number
Most countries answer "what's the fine?" with a figure. Spain can't — by design. Its transposition, Ley 11/2023, does two unusual things at once:
- No national regulator. Under Article 27, each of Spain's 17 Autonomous Communities plus the cities of Ceuta and Melilla designates its own vigilance authority — up to 19 different regional bodies, each applying the penalty regime independently.
- No unified penalty. Article 30 doesn't set euro amounts. It sends each breach to the sanctioning law of the sector it falls under, with the general disability law as a backstop.
So your real exposure in Spain is a function of two variables — your sector and your region — not a single published ceiling.
What the law says
Article 30 is the key text, and it's worth reading because it contains no numbers at all:
"1. Los incumplimientos de lo dispuesto en el presente título serán sancionados conforme al régimen de infracciones y sanciones establecido en la legislación sectorial correspondiente. En lo no previsto en la legislación sectorial, se aplicará de manera supletoria el título III del Texto Refundido de la Ley General de derechos de las personas con discapacidad y de su inclusión social, aprobado por el Real Decreto Legislativo 1/2013, de 29 de noviembre."
("1. Breaches of this Title shall be penalised in accordance with the regime of infringements and penalties established in the corresponding sectoral legislation. Where the sectoral legislation does not provide for it, Title III of the consolidated General Law on the Rights of Persons with Disabilities, approved by Royal Legislative Decree 1/2013, shall apply as a supplementary regime.")
— Ley 11/2023, Art. 30(1) (BOE)
Article 30(2) also carves out public procurement (contracts under Ley 9/2017 are handled separately).
So what would you pay?
It depends entirely on the sector:
| Your situation | Which law sets the fine | Most serious breaches |
|---|---|---|
| No sector rule covers the breach | RDL 1/2013, Title III (general disability law) | Up to €1,000,000 |
| Online shop / e-commerce | LSSI (Ley 34/2002) | Roughly €150,001–€600,000 |
| Banking, telecoms, transport | That sector's own sanctioning law | Varies by sector |
- The fallback (RDL 1/2013). Where no sector rule applies, the general disability law's Title III governs, with graded fines running up to €1,000,000 for the most serious infringements. This is the source of the "€1,000,000" figure you'll see quoted for Spain — but it's the backstop, not a universal EAA fine.
- A sector example (e-commerce). An online-shop breach may instead fall under Spain's e-commerce law (LSSI, Ley 34/2002), where the most serious infringements run roughly €150,001–€600,000.
- Other sectors — banking, telecoms, transport — each carry their own sanctioning regimes and their own numbers.
The bottom line: anyone quoting you a single flat "Spain EAA fine" hasn't read Article 30. The first question is always which sector, which region.
Who enforces it
There's no national accessibility regulator. Each Autonomous Community designates its own vigilance authority to run market surveillance, verify conformity, and apply the penalty regime. Sitting above them is a Technical Unit (created by Royal Decree 143/2026, in February 2026) that coordinates the regional authorities and acts as a national point of contact for complaints — but it is advisory and coordinating, not a primary enforcer, and it only acts as the regulator itself in a region that hasn't designated one.
One consequence worth flagging: the Technical Unit didn't legally exist until early 2026 — nearly three years after the law was passed — which is part of why Spanish enforcement has looked quieter than France's or Germany's.
Spain also has a public-interest litigation route. Under Article 29(2), consumers, representative organisations, and "legal persons with a legitimate interest" can go directly to administrative bodies or the courts to demand compliance — the same pattern seen in Ireland.
Has it been enforced yet?
No confirmed EAA sanctions have surfaced in Spain, and the fragmented structure plus the late-arriving coordination unit make a headline national case less likely in the short term than in France. But the regional authorities have full power to act, the sectoral fine schedules already exist and are well established, and the public-interest litigation route is open now.
What this means for your business
For Spain, skip the search for a single number — it doesn't exist. Instead:
- Identify which sector law governs your product or service, because that determines your fine exposure.
- Know which Autonomous Community you operate in, because that's who enforces.
- Get to EN 301 549 / WCAG 2.1 AA regardless, since the accessibility standard is uniform even though the penalties aren't.
If you sell across multiple Spanish regions, assume you're answerable to multiple authorities.
Frequently asked questions
What is the EAA fine in Spain?
There isn't a single one. Spain's law defers to each sector's own sanctioning law, with the general disability law (RDL 1/2013) — fines up to €1,000,000 — as a fallback where the sector law is silent.
Is Spain's EAA fine €1,000,000?
That's the fallback maximum under the general disability law, not a universal figure. Many breaches are punished under sector-specific laws with different amounts (e.g. up to ~€600,000 for serious e-commerce breaches).
Who enforces the EAA in Spain?
Up to 19 regional authorities — one per Autonomous Community plus Ceuta and Melilla — coordinated (since 2026) by a national Technical Unit that is advisory rather than a primary enforcer.
Can consumers or groups take action directly?
Yes. Article 29(2) lets consumers, representative organisations and parties with a legitimate interest go to administrative bodies or courts to demand compliance.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Ireland's EAA fines — the opposite extreme: one criminal regime, six regulators
- How we verified all 27 national laws — why "which law sets the fine" is the question we always ask
