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Spain: Companies must adapt their recruitment, training, and work processes for certain employees with intellectual disabilities

Spain - 

The Regulations on basic cognitive accessibility conditions, which take effect on January 2, 2027, require companies, in the employment context, to ensure that job postings are accessible, to facilitate accommodations during interviews as well as in documents and work meetings, and to provide reasonable accommodations and support where employees demonstrate a degree of disability of 33% or higher and an intellectual disability.

Royal Decree 707/2026, of September 2, 2026, approving the Regulations on basic cognitive accessibility conditions, sets out the basic cognitive accessibility conditions applicable throughout Spain and establishes specific employment-related obligations for companies where workers provide proof of a disability rating of 33% or higher and an intellectual disability through the certificate referred to in section 1 of Additional Provision 1 of Royal Decree 888/2022. 

These measures include most notably the following:

  • Training and onboarding. When requested, training provided by the company must comply with cognitive accessibility recommendations and provide documentation in easy-to-read language and alternative formats. In addition, the materials used in occupational risk training, as well as those covering emergency procedures and protocols, must include an easy-to-read version. Companies are also expected to provide easy-to-read guides or manuals and to designate a support person to assist new employees during their onboarding and adjustment to the job.
  • Access and recruitment. Job postings as well as their terms and requirements must be published in an accessible format and, in all cases, in plain language. Accommodations for the interview may be requested at no cost.
  • Time recording systems. Time recording and authentication systems used through a company's electronic portal must allow access without requiring users to remember a password, provide an alternative authentication method tailored to the individual's cognitive abilities, implement double-verification mechanisms for the submission of information, and ensure the availability of remote assistance. 
  • Accommodations for documents, meetings, and working conditions. Employees may request accommodations for the documents necessary to perform their assigned tasks and for the meetings in which they participate. In turn, the company must provide such accommodations unless doing so would impose a disproportionate burden. If it does, the company must notify the employee in writing and in a cognitively accessible manner.
  • In addition, the company must provide, upon request and with the employee’s participation, support systems and reasonable accommodations regarding, among other things, schedules, allotted time, workload, and the use of assistive technologies, and it must review them periodically.

The Regulations will take effect on January 2, 2027.