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Accessibility (A11Y): from an ethical recommendation to a legal requirement with real consequences

Since June 28, 2025, digital accessibility is no longer an optional “nice to have”: it is a legal requirement affecting companies that offer digital products or services to the public in Spain and across the EU.

This applies, among others, to websites, mobile apps, digital documents, client/patient portals, and other digital interfaces that enable access to your organization’s services.

Mandatory timelines (Spain/EU)

  • New digital products or services launched from 28/06/2025 onward: they must meet accessibility requirements from day one (WCAG guidelines and/or the UNE-EN 301549 standard, depending on the case).
  • Products and services that already existed before 28/06/2025: there are transitional periods in certain scenarios, often referencing an adaptation horizon up to 28/06/2030 (for example, due to continuity of previous contracts or the use of certain already-implemented products).

This means that any major redesign or new launch from that date requires compliance from the first day.

Who is required to comply (company profiles)?

The regulation is broad and not limited to the tech sector. In general, organizations must comply if they offer the public products or services that fall within the scope of the rules (for example, digital channels for support, contracting, or purchasing, among other common cases).

  • Businesses with a digital presence that interacts with customers or users (website, app, private area, application/registration flows, forms, etc.).
  • Micro-enterprises: there may be specific exemptions in certain scenarios, as well as the possibility of claiming “disproportionate burden” in specific cases. Even so, it’s worth reviewing carefully because it does not always apply in the same way to products as it does to services.

What about the healthcare sector?

Accessibility has an especially high impact in healthcare services where digital interaction is critical for accessing care. In practice, this usually means reviewing (and adapting) areas such as:

Dental clinics

  • Accessible booking websites and accessible forms/consents
  • Treatment information accessible for people with visual or cognitive disabilities

Fertility clinics

  • Accessible registration interfaces and result-checking portals
  • Clinical-legal documentation in clear, understandable formats

Ophthalmology

  • Websites and apps compatible with assistive technologies
  • Barrier-free navigation for people with visual impairments

Aesthetic medicine

  • Accessible informed consents
  • Procedure and risk content that is readable and usable

All of this not only improves the patient experience: in many scenarios, meeting accessibility guidelines is a regulatory requirement and a key element of risk management.

Penalties and consequences of non-compliance

The rules include a real and proportionate enforcement regime. Depending on severity and repeat offenses, it may involve:

  • Financial penalties: from significant amounts to very high figures in serious cases.
  • Urgent remediation obligations for digital services.
  • Possible restrictions in tenders or access to grants/subsidies, depending on the case.
  • Reputational damage with patients and users.

Conclusion

Digital accessibility is no longer merely a best-practice recommendation:

  • It is a legal obligation for new services from 28/06/2025.
  • There are transitional timelines in certain scenarios for existing services or products, with common references to adaptation by 2030.
  • Non-compliance can lead to penalties, mandatory fixes, and reputational or competitive consequences.

In sensitive sectors like healthcare, accessibility is a strategic requirement that directly impacts patient experience, regulatory compliance, and risk management.

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