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Your Training Videos and the European Accessibility Act: What You Actually Need to Comply With
Maialen Carrasco
Customer Success
Digitization
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 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.
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.
The figure that makes this obligation very concrete: 6.2% of Spain's active working population has a recognized disability.^1 Companies with more than 50 employees must reserve at least 2% of their positions for people with disabilities (LISMI quota). For a 200-person company, that's four employees for whom accessible training isn't optional — it's a right.
Penalties for non-compliance with the LGDPD reach up to €1,000,000 for very serious infringements, plus possible suspension of operations.^2
Beyond the LGDPD, there are other contexts where the accessibility of your training may already be subject to requirements:
State-subsidized training (FUNDAE). If you use FUNDAE credits to fund training, the platform you use must comply with technical standard EN 301 549 — the digital accessibility reference in European public procurement. Platform accessibility is a condition for subsidy eligibility. Here's how to optimize FUNDAE credits with AI video training.
Public procurement. If your company provides training to public bodies or works with government agencies, EN 301 549 applies directly to the content you deliver.
Cultural and reputational context. 98% of Spanish private companies still don't meet digital accessibility standards.^3 At a time when ESG criteria and inclusion policies are part of corporate discourse, inaccessible training is also a reputational exposure. Here's a guide for auditing whether your corporate training is genuinely inclusive.
The technical reference standard for digital accessibility is WCAG 2.1, level AA. For video content, the four most relevant criteria are:
| Criterion | Level | What It Means |
|---|---|---|
| 1.2.2 — Captions for Pre-recorded Video | A (minimum) | Synchronized captions on all recorded video content |
| 1.2.4 — Live Captions | AA | Real-time captions if you run live training sessions |
| 1.2.5 — Audio Description | AA | An additional audio track describing visual content: what each slide shows, what the graphic contains, what the presenter is doing. This isn't a script narration — it's a descriptive layer for anyone who can't see the screen |
| 1.4.3 — Contrast | AA | Minimum 4.5:1 ratio for text and overlays on video |
For an L&D team starting from scratch, what's useful isn't knowing these criteria exist — it's knowing what order to tackle them.
First priority: captions (1.2.2). This is the Level A criterion — the minimum requirement — and the one that comes up most often in audits and complaints. It has the most manageable implementation effort and the broadest impact: it benefits people with hearing disabilities, employees working in a second language, and anyone watching the video without sound. If you can only do one thing, this is it.
Second priority: audio description (1.2.5) for high-impact content. This requires planning visual content with a description layer in mind — which typically means revising scripts and redesigning modules. There's no point tackling it across the entire catalog at once. The sequence that works best: apply it first to the highest-criticality training — compliance, health and safety, onboarding — before extending it to the rest.
Contrast and navigability (1.4.3 and keyboard playback) are usually resolved at the template and player level. They are global fixes that affect the entire catalog without needing to review video by video.
The typical mistake is treating accessibility as a separate project: reviewing the existing catalog, hiring a captioning service, updating videos one by one. That's reasonable for a historical archive — but it doesn't have to be the model for new content.
For new content, the most immediate lever is integrating captioning into the production workflow itself — not as a post-production review, but as a standard output of whichever tool you use to create the video. What to look for: captions that are automatic, editable before publishing, and available in the languages you need. Editability matters especially in technical training — a mistranscribed term can cause confusion or, in safety training, something worse.
Following the priority sequence from the section above — captions first, audio description on critical content next, contrast and navigability at the template level — lets you move forward without stalling your regular production.
If your company has more than 50 employees and uses video-based training, these are the three most immediate steps:
The third point is the one most often skipped — and the one that comes up first when there's a complaint.
This week we also published an article on Article 4 of the EU AI Act, which requires a different type of mandatory training before August 2: How to design an AI literacy training plan for your workforce.
^1 INE, El empleo de las personas con discapacidad 2023. https://www.ine.es/dyngs/INEbase/es/operacion.htm?c=Estadistica_C&cid=1254736055502&menu=ultiDatos&idp=1254735976595 ^2 Royal Legislative Decree 1/2013, of 29 November, approving the Consolidated Text of the General Law on Rights of Persons with Disabilities. ^3 COCEMFE / Web Accessibility Barometer 2025. https://www.cocemfe.es
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