Illustration in papyrus and graphite tones, with a polygonal aesthetic. Before an open and illuminated entrance, two stone panels: one tall, covered in tiny, illegible marks; another smaller one, with three large and clear shapes.

Public Notebook

Before the visit

State-owned museums are still governed by a 1987 regulation. The words 'disability' and 'accessibility' do not appear in its current text. The preamble refers to citizens' access 'on equal terms throughout Spanish territory'. The articles on visiting regulate minimum opening hours, conditions of entry, free days and the possibility of setting reduced prices for certain groups. It is a text in which access to the museum is conceived mainly as opening to the public and a system of admission.

The Ministry of Culture put a new regulation out for public consultation between 22 December 2025 and 14 January 2026. As of 4 October 2026, its approval has not been recorded in the Official State Gazette (BOE).

During that consultation, CERMI, which represents disabled people in Spain, submitted a report containing seventeen observations. The organisation made its proposals public on 9 February 2026. It called for universal accessibility to be made a cross-cutting and enforceable requirement: ensuring physical, sensory, communicative, cognitive and digital accessibility; making all museum communications, both on-site and online, accessible through measures including subtitling, audio description and easy-to-read formats; training staff; designing accessible spaces from the outset; and periodically assessing accessibility across the museum system.

For many people, the visit begins before they reach the door: on the website where they check opening hours, prices, how to get there and what they can find inside. If that information is not understood, the visit may not happen. This exclusion leaves hardly any trace, because nobody records those who give up before arriving.

This is the terrain of 'Easy Access, Inclusive Society: Digital Innovation from the Community', a project announced by Plena inclusión on 29 April 2026. Twenty exploration teams, formed within fifteen federations and the Asociación Líber, are assessing the cognitive accessibility of public leisure, culture and tourism websites. Each team first reviews a website from its own territory and then a prototype of an accessible website. Participants include people with and without difficulties in understanding, cognitive accessibility professionals and community agents. The project is being developed in collaboration with the HULAT group at Universidad Carlos III de Madrid and with financial support from the Ministry of Social Rights, Consumer Affairs and Agenda 2030 and the ONCE Foundation. Its two expected outputs, a study and a tool with recommendations, have not yet been published.

The accessibility of public websites is regulated by Royal Decree 1112/2018. The standard requires that their content be perceivable, operable, understandable and robust, and refers to the applicable European technical standards. It does not, however, formulate a distinct obligation under the term 'cognitive accessibility'.

This does not imply that cognitive accessibility lacks legal recognition. Law 6/2022 expressly incorporated it into universal accessibility and extended its application to, among other areas, the information society, goods and services available to the public, and cultural heritage. Royal Decree 707/2026 developed its basic conditions and was published on 3 September 2026, although it will enter into force on 2 January 2027. Furthermore, an act published on 3 October 2026, which will enter into force twenty days later, reinforces universal accessibility as a right and adds to the Spanish Historical Heritage Act a specific obligation to guarantee it within cultural heritage, including cognitive accessibility and reasonable adjustments.

Web accessibility is often checked against verifiable technical criteria: whether images have alternative text, whether the site can be navigated with a keyboard or whether the contrast is sufficient. These are necessary conditions. Meeting them does not, by itself, show that a person can understand how to prepare a visit or buy a ticket.

Plena inclusión's method introduces another check: observing what the people who use the website understand and how they find their way around it. It does not replace technical evaluation; it examines a barrier that the latter may fail to detect. The future museum regulation may spell out these obligations for the museum sector, but cognitive accessibility no longer depends only on the will of each institution. It has legal recognition and, from January 2027, will also have specific state regulations implementing it.

About the open conversation

This text continues the Notebook's line of enquiry into the infrastructures that decide who gets to culture, now from the digital entrance. It starts from the regulation currently in force, the draft meant to replace it, CERMI's proposals, Plena inclusión's project and the legal framework for cognitive accessibility. If you work in accessibility, in museum mediation or in one of the evaluation teams and can contribute a data point, this notebook remains open.

Updated on 4 October 2026: the number of CERMI's observations and the date on which the organisation made its proposals public have been specified, and the full text of the draft regulation has been linked.

Sources

Royal Decree 620/1987, of 10 April, approving the Regulations for State-Owned Museums and the Spanish Museum System

Ministry of Culture, public consultation on the draft royal decree for the Regulation of state-owned museums and the Spanish Museum System

Ministerio de Cultura, proyecto de real decreto del Reglamento de los museos de titularidad estatal y del Sistema Español de Museos (texto completo)

CERMI, 'CERMI proposes that the Ministry of Culture strengthen universal accessibility and the inclusion of persons with disabilities in the future regulation of state museums'

CERMI Diario, «El CERMI pide a Cultura asegurar la accesibilidad física, sensorial y cognitiva en los museos»

Plena inclusión, 'Building Accessible Communities will assess the cognitive accessibility of public leisure, culture and tourism websites in 2026'

Universidad Carlos III de Madrid, 'UC3M collaborates with Plena inclusión on a project to improve cognitive accessibility on public culture, leisure and tourism websites'

Royal Decree 1112/2018, of 7 September, on the accessibility of websites and mobile applications for the public sector

Law 6/2022, of 31 March, establishing and regulating cognitive accessibility and its requirements and application conditions

Royal Decree 707/2026, of 2 September, approving the Regulations on the basic conditions for cognitive accessibility

Law 4/2026, of 1 October, for the extension and reinforcement of the rights of persons with disabilities


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