SaaS design agency in Spain: what to check before you sign

Product DesignSep 1, 20268 min read

Since June 2025, Spain's Ley 11/2023 puts accessibility duties on private digital products, with sanctions reaching one million euros. Six questions to ask.

In this piece

Hiring a design agency for a SaaS you sell in Spain is now partly a compliance decision. Since 28 June 2025, Ley 11/2023 has extended accessibility duties to private-sector digital products and services, and the sanctioning regime it points to reaches one million euros for the most serious infringements. Most pitch decks in this market still open on visual work. This piece gives you six questions to run on a shortlist, the answers that pass, and the answers that tell you to keep looking.

What to have ready before the first call

Four facts decide which obligations apply to you. Collect them before you talk to anyone. An agency that asks for them unprompted has already told you something.

Who you sell to in Spain. Consumers, businesses, or public administration. The duties differ.
Headcount and turnover. Microenterprises, under 10 people and under two million euros, sit outside most of the service obligations in Ley 11/2023.
Whether end users touch an AI feature. If they do, part of the disclosure lands in the interface.
Whether you issue invoices to Spanish customers from inside the product. That pulls a second body of rules onto your screens.

Note the state of what you already own too: Figma files, a coded component library, or neither. That answer sets the scope of a first engagement more than any brief will.

1. Which accessibility standard do you build against, and which version?

Ley 11/2023 transposes EU Directive 2019/882. The technical yardstick behind it is EN 301 549. The version in force, V3.2.1 from March 2021, maps to WCAG 2.1 level AA. A revision aligned with WCAG 2.2 AA has been through public review and is expected to be cited in the Official Journal during 2026, per the W3C policy tracker.

A usable answer names the standard and the version. Then push past alt text, which every agency mentions. Ask how they handle focus order on a dashboard with forty interactive elements, how they identify errors on a multi-step form, and what minimum target size they draw buttons to. Those are the criteria real SaaS products fail. Agencies that have shipped against the standard answer in specifics inside thirty seconds.

Ask what happens after handover as well. Accessibility decays with every release, and a conformance statement written in March means nothing in November unless somebody tests. We went through the mechanics in accessibility-first design after the EU Accessibility Act.

2. Who designs, by name, and for how many hours a week?

The people in the pitch are often not the people on the work. Ask for names. Ask what each of them shipped on their last three projects. Ask for the weekly hour commitment to be written into the statement of work rather than promised on a call.

Then ask the uncomfortable one: what happens if that designer leaves in month three. A studio with a real answer describes a handover file and a second person already reading the project. A studio without one changes the subject.

3. What do you hand over besides Figma?

A Figma file nobody converts is a cost. Ask what arrives in the repository: design tokens in a machine-readable format, coded components, or a PDF of screens. Ask to see a token file and the component that consumes it, taken from a real project, with the client name redacted if it has to be.

Most of the money leaks here. Teams pay twice, once for the design and once for the engineering that reinterprets it. The seven categories of a design system make a decent script for this question: ask which ones they deliver and which ones you inherit.

4. How do you handle Spanish, and which Spanish?

Register comes first. Spanish SaaS products aimed at founders and small teams have used tú since the mid-2000s. Banking, insurance, enterprise and public sector still expect usted. An agency that has not asked which one you want has not written product copy in Spanish.

Then the mechanics. Numbers carry a comma decimal and a period thousands separator: 2.500,50. Dates run day first. Spanish strings sit longer than their English source, which breaks fixed-width buttons, tabs and table headers drawn on English copy. And if you sell to public administration in Catalonia, Galicia, the Basque Country, Valencia, the Balearics or Navarre, co-official languages stop being a preference and become a procurement requirement.

5. Which rules reach into the interface?

Two are live right now for a product sold in Spain.

The AI Act. Since 2 August 2026, obligations for high-risk systems and transparency duties for general-purpose models apply, and AESIA, the Spanish supervisory agency created by Real Decreto 729/2023 and based in A Coruña, holds full market-surveillance and sanctioning powers (Oficina Nacional de Emprendimiento). Telling a user they are interacting with an AI system is an interface problem before it is a legal one. Whoever draws your screens owns part of it.

Verifactu. If your SaaS issues invoices for Spanish customers, the invoicing rules land on your screens. Real Decreto-ley 15/2025, published in the BOE on 3 December 2025, moved the obligation to 1 January 2027 for corporate income tax payers and 1 July 2027 for everyone else (Civio). That is a design brief with a deadline attached: verifiable invoice records, QR codes on documents, and a visible state for records already sent to the tax agency.

You are not hiring a law firm, and neither question expects a legal opinion. You are testing whether the agency knows the constraints exist before it hands you a layout that cannot carry them.

6. Who owns the output when the contract ends?

Ask three things in writing. Does IP assign on payment or on final delivery. Do you receive source files, including the Figma project and the token repository, or view access only. And if they build you a design system, who owns it, who can license it, and what happens when you hire an in-house team next year. Design system pricing splits along exactly these lines, so the ownership answer usually predicts the price.

What stopped being a signal

Kit Digital is over. Applications for the final calls closed on 31 October 2025 and the programme finished after three years. An agency still leading with Kit Digital funding in 2026 is quoting a subsidy that no longer opens, which tells you how recently it updated its offer.

Two more carry less weight than their placement on a homepage suggests. Awards measure one jury's taste on one artefact. Headcount measures payroll. Neither predicts whether the person assigned to you is still there in month six.

How to test the answers before you sign

Buy a small piece of work first. One screen, two weeks, a fixed fee, and a brief you write rather than one they propose. Pick the ugliest screen you have, the one with the table, the filters and the error states. Pretty screens hide everything.

Score four things when it lands. Did they ask questions before designing. Did the delivery include tokens and a working component, or only an image. Does the screen survive a keyboard-only pass. Did the named designer do the work. A paid trial costs less than three weeks of a bad retainer and answers what a reference call cannot. For the ranges these engagements sit in, see product design retainer pricing.

Common failures and how to fix them

The brief arrives as a feature list. Rewrite it as the three decisions you need help making. A feature list gets priced by volume. A decision gets a plan.
Accessibility gets scoped as a final audit. Retrofitting costs more than designing for the standard, and an audit two weeks before launch produces findings nobody has time to fix. Put the standard in the statement of work on day one.
Nobody names the reviewer on your side. Two decision-makers with different taste stall a project longer than any technical problem does. Name one.
The contract has no exit. A retainer without a 30-day notice clause and a handover obligation locks you into a relationship you can only leave badly.

Sources

Photo by Deyan Sight ↗ on Unsplash ↗

Frequently asked questions

Does Ley 11/2023 apply to a foreign SaaS sold in Spain?+

Yes, if you place the product or service on the Spanish market. The law transposes EU Directive 2019/882, which follows the market rather than the seat of the company, so a SaaS incorporated in Delaware or Milan and sold to Spanish consumers falls inside the scope. The microenterprise exemption, under 10 people and under two million euros, is measured on your company, not on your Spanish revenue. Software sold only to other businesses sits outside most of the consumer-facing duties, though a B2B product with a public-facing surface rarely stays cleanly on one side.

Should I hire an agency based in Spain or one that knows the market from outside?+

Location matters less than two things: whether the team has shipped against EN 301 549, and whether it has written product copy in Spanish for the register you need. A studio in Berlin that has delivered an accessible Spanish-language product beats a Madrid studio that has done neither. Where being local does help is procurement with public administration, where paperwork, co-official languages and in-person meetings are part of the process. Ask for one shipped Spanish-language product before you weigh the address.

Who is liable if the agency delivers an inaccessible product?+

You are, in front of the authorities. Ley 11/2023 puts the duty on the economic operator that offers the product or service, not on its suppliers. What the contract can do is move the cost: a warranty on conformity with EN 301 549, a remediation obligation at the supplier's expense for defects found within an agreed window, and acceptance criteria that include an accessibility test rather than a visual sign-off. Ask for those clauses at proposal stage. An agency that refuses them is telling you it has never been measured on this.

How long should the vetting process take?+

Two to three weeks for the conversations, plus two weeks if you run a paid trial. Faster than that and you are buying a portfolio. Much slower and you lose the candidates worth having, because good studios book out and will not hold a slot through a six-week committee. A workable rhythm: a first call with three or four agencies in week one, the six questions in week two with the two that survive, and a paid single-screen trial with one of them in weeks three and four.

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