Your Training Videos and the European Accessibility Act: What You Actually Need to Comply With

When someone on the team says "we need to make our training videos accessible because of the European law," the first useful question is: which law, exactly?

Because accessibility in corporate training falls under several distinct legal regimes — and they don't all point to the same type of content. Confusing them leads to two equally costly mistakes: ignoring real obligations that already exist, or launching an oversized accessibility project for a regulation that, strictly speaking, doesn't apply to internal training.

This article clarifies what requires what — and what you can do right now.

 

The EAA in 60 Seconds — and Why It Doesn't Directly Apply to Your Internal Training

The European Accessibility Act is Directive (EU) 2019/882, transposed in Spain through Law 11/2023. It's been in force since June 2025 and sets accessibility requirements for digital products and services offered to the market: online banking, e-commerce, transportation, media, consumer software.

The nuance most L&D teams miss is twofold. On one hand, the Directive's material scope is limited to specific consumer-facing products and services: the sectors listed in its Annexes include banking, e-commerce, transport, telecommunications, and audiovisual media — internal training does not appear among them. On the other hand, Recital 11 clarifies that B2B services provided to natural persons in their professional capacity fall outside the scope. An internal LMS, a video training library for employees, a corporate onboarding platform — these are not consumer services. None of them fall directly within the EAA.

Micro-enterprises with fewer than 10 employees and less than €2 million in turnover are also fully exempt.

The distinction between which law applies is not a minor technicality. The EAA establishes obligations for digital products and services in the market — it starts from the company-to-consumer relationship, and its enforcement mechanism is market supervision. The LGDPD operates from an entirely different logic: it starts from the employment relationship and the principle of equal opportunity at work. Correctly identifying the applicable framework changes who bears the responsibility, what documentation you need to have ready, and which inspection channel could act. Inaccessible internal training is not a breach of market regulation — it is a potential violation of labor rights.

 

The Law That Actually Applies: LGDPD

Spain's General Law on Rights of Persons with Disabilities (Royal Decree 1/2013) requires employers to make reasonable adjustments in the workplace for employees with disabilities. That includes training. If an employee with visual, hearing, or cognitive disabilities can't access the training content that everyone else can, that's a breach of the reasonable adjustment principle — regardless of whether the LMS is internal.