Online store accessibility in Spain: what to check

Reviewing an online store's accessibility means following a purchase: search, compare, choose, add to cart, sign in and pay. An accessible homepage cannot compensate for a form that prevents checkout.

Spain also has a legal framework to consider. Separate which services are covered, which exemptions may apply and which criteria the website is tested against.

What Spain's Law 11/2023 covers

Title I of Law 11/2023 includes ecommerce services and has applied since 28 June 2025. Its transitional provisions are not a blanket extension for every existing store.

The law exempts microenterprises providing services from that title's accessibility requirements. The definition combines fewer than ten people with annual turnover or an annual balance-sheet total no greater than two million euros. Turnover alone is not the full test, and the web developer's size does not establish the client's exemption.

Assess the actual service provider before relying on an exemption. It should not be treated as removing every other possible accessibility obligation.

WCAG and EN 301 549 serve different purposes

WCAG 2.2 provides testable web accessibility criteria. Using its A and AA levels gives a clear basis for design, evaluation and remediation.

ETSI has published EN 301 549 V4.1.1, dated September 2026. Publishing a standard and citing its reference in the Official Journal for a particular directive are separate steps. Any report relying on a presumption of conformity should identify the applicable legal reference, scope and date.

An audit therefore needs to state exactly what it evaluated. “Accessibility compliant” is too vague without the pages, processes, criteria, results and limitations behind it.

Start with a complete purchase

Choose a product with variants and use the payment methods you actually offer.

Test with a keyboard, magnification and assistive technology. Include third-party components such as payment, consent, chat and authentication.

An initial review can uncover barriers without establishing full conformance. W3C makes that distinction in its preliminary checks guidance.

What to ask for in an audit

Choose a scope covering templates and processes, not simply a URL list. A standard product page and one with a configurator may need different tests even if their design is shared.

Each issue should explain how to reproduce it, who it affects, which criterion is assessed and how to verify a fix. Start practical remediation with barriers that block tasks while tracking the other requirements in scope.

Combine automated tools with manual evaluation. The report should make it possible to repeat the same journey after fixes and significant store changes.

Decisions to make during design

Allow space for understandable errors and loading states. Make variant selection work without relying solely on colour. Define how dialogs open, close and return keyboard focus.

If you add a 3D configurator, retain an accessible way to inspect options and buy. Visualisation should support the purchase without becoming its only route.

To review an existing store, send us its URL and main purchase journey.