On 28 June 2025, Member States can start enforcing the European Accessibility Act ("EAA") – a deadline which may have crept up on some firms in the banking and financial services sector. The EAA applies to a broad range of financial services and associated digital technologies, from payment terminals to online banking platforms. This means banks, payment services providers, e-money and other providers of financial services to retail customers must review their customer interfaces, products and related documentation to ensure compliance. If EAA compliance has slipped down your "to do" list, now is the time to act. As we discuss later in this briefing, businesses operating in the UK market also cannot afford to be complacent about accessibility.
1. What's the EAA's scope?
From a financial services perspective, the products and services that are in scope of the EAA include:
- Self-service terminals (e.g. payment terminals, ATMs and information screens).
- Consumer banking services. These include credit agreements (consumer loans and mortgages), payment services, payment account-linked services, electronic money and certain investment services.
- E-commerce services. Websites or apps for products and services sold to EU consumers.
Member States have discretion to implement measures in relation to the built environment used for consumer banking services (which we do not consider further in this briefing).
The EAA imposes obligations on service providers, as well as on manufacturers, importers and distributors of ATMs and payment terminals. It focuses on whether the consumer is in the EU, not on where the firm is based.
"Persons with disabilities" is deliberately broadly defined:
persons who have long-term physical, mental, intellectual or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others
The preamble to the EAA notes that it will therefore benefit a wide range of people (e.g. elderly people)
2. What are the accessibility requirements?
The EAA sets out minimum requirements and Member States can adopt additional ones, so it is important for firms to familiarise themselves with national implementing measures in the territories in which they operate. The European Commission has a tracker of national laws, which transpose the EAA requirements.
There are general accessibility requirements, which are prescribed in Annex 1 to the EAA separately for products and services, e.g.:
- Products and services (as well as support services such as call centres or helpdesks) must be provided with information about their use and interoperability with assistive devices. The information must be understandable, made available via more than one sensory channel, and clearly presented.
- Products (here, self-service terminals) must contain features, elements and functions that allow people with disabilities to use, understand and control the product. For example, where the product uses speech, there must be alternatives to speech input and, where the product uses visual elements, it must provide for flexible magnification, brightness and contrast.
There are then additional specific requirements for certain products and services, so (again, only as examples):
- Providers of consumer banking services must ensure that:
(i) their websites and any online applications are perceivable, operable, understandable and robust so that they are easily accessible in a consistent and adequate manner;
(ii) the language used does not exceed the "upper intermediate" level of complexity set out in the Council of Europe's Common European Framework of Reference for Languages; and
(iii) identification methods, electronic signatures, security and payment services are perceivable, operable, understandable and robust.
- Manufacturers of ATMs or payment terminals must ensure that the products:
(i) support text-to-speech technology;
(ii) allow use of headsets and, where there's audio, the use of hearing assistive devices; and
(iii) allow consumers to extend time limits and use more than one sensory channel to notify consumers where there is a time limit.
3. Are there any exemptions?
There are some exclusions:
- Existing self-service terminals may be used until the end of their lifespan (maximum 20 years).
- Microenterprises with fewer than ten employees and under €2 million turnover are exempt from some requirements.
- Disproportionate burden. If meeting the requirements would fundamentally alter the product or service or place a disproportionate burden on the provider, a narrowly drawn exemption may be available—provided it is documented and notified to competent authorities.
4. What are the consequences of non-compliance?
Penalties are determined at the Member State level, but may include significant fines and, in the most extreme cases, withdrawal of non-compliant products and services and personal liability for company officers. Reputational risk and potential legal action from consumers or consumer bodies are also factors to consider.
5. What about businesses operating in the UK?
While the UK is not enacting EAA-equivalent legislation, accessibility remains a critical issue for firms operating in the UK under the Equality Act 2010 and the FCA's Consumer Duty. This means UK-based firms—not only those operating in the EU—should also focus on accessible service design, reasonable adjustments for disabled users, and ongoing monitoring of customer outcomes.
6. Equality Act
The Equality Act aims to protect people with certain protected characteristics from direct and indirect discrimination, victimisation and harassment.
Under the Equality Act, firms are required to: (i) make reasonable adjustments to ensure disabled individuals have equal access to its services, including websites and mobile apps; and (ii) address any substantial disadvantage faced by disabled users. Although 'services' are not defined, they have been widely interpreted and include financial services.
One way of demonstrating that the consumer banking elements of websites and mobile apps are accessible would be to comply with the Web Content Accessibility Guidelines ("WCAG"). Although the WCAG is not legally binding, it offers best practice for improving accessibility. The core principles of the WCAG are ensuring that web content is: (i) perceivable, (ii) operable, (iii) understandable, and (iv) robust.
The FCA's 'Consumer Duty' sets the standard of care that firms should provide to consumers. The Consumer Duty requirements are generally expressed in high-level, principles-based terms and are outcomes-driven (rather than being prescriptive). However, the FCA has certain expectations of what firms should be doing, for example:
(i) providing information relating to products and/or services in an accessible format
(ii) monitoring and identifying instances where customers with vulnerabilities or protected characteristics consistently experience poorer outcomes
(iii) taking steps to address any issues that are identified to ensure products and services meet consumers' needs.
Opportunities for innovation
There is therefore a divergence in the strategic approach taken in the UK (i.e. principles-based and outcomes-driven) versus the EU's more prescriptive approach.
In addition, from a philosophical perspective, the EAA tends to focus on the limitations of existing technology. In the UK, there is a greater recognition (including by regulators and supervisors) of the opportunity offered by technological innovation, and that offers a chance for businesses operating in the UK market to contribute to innovative solutions to accessibility challenges.
What next?
Legacy systems, complex user interfaces, multiple platforms, frequent updates to maintain security – ensuring accessibility in the financial sector is a challenge, but it's one that firms must embrace. If accessibility has been in the "to do" pile for too long, there is no time to lose in taking implementation steps:
- Map affected products and services. Identify the offerings in scope and assess current compliance. This should include checking relevant national laws.
- Document exemptions. If the firm is relying on exclusions, ensure robust documentation and notification procedures are in place.
- Regular accessibility testing. Periodic user testing can help identify where adaptations are needed and demonstrate compliance with regulatory expectations.
- Internal, ongoing training. Ensure staff are aware of accessibility requirements and their practical application.
- Accessibility statement. Develop and publish a clear statement on your firm's approach to EAA compliance and accessibility, available in accessible formats.
To conclude on a positive note, accessibility compliance is an opportunity for firms to access a wider, more diverse customer base, enhance their reputation and increase customer loyalty and trust.
This briefing was prepared with the assistance of Jade Wheeldon-Scully, trainee.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
