The European Accessibility Act (EAA) The European Accessibility Act (Directive (EU) 2019/882) applies to a range of services, including banking services, and imposes two distinct categories of obligations:
- Technical Accessibility Requirements: Ensuring services are designed and delivered in an accessible manner as defined in Annex I.
- Administrative Obligations: Documentation, declarations, public information, and cooperation with authorities.
Administrative Obligations for Banking Service Providers
Banking service providers fall under the category of service providers and must meet the following administrative requirements:
Required by Article 13 of the EAA (specifically for service providers):
Service providers shall ensure that services they provide comply with the accessibility requirements set out in Annex I.
They shall prepare the necessary information in accordance with Annex V and explain how the services meet the applicable accessibility requirements.
They shall make this information available to the public in written and oral formats, including in a manner accessible to persons with disabilities.
They shall, upon reasoned request from a competent authority, provide such authority with the information referred to in paragraph 2 in paper or in an accessible electronic format.
Summary of Administrative Obligations:
- Conformity Explanation: Prepare a public-facing explanation of how banking services meet the Annex I accessibility requirements.
- Documentation Format: Provide this explanation in both written and oral formats, and ensure it is accessible to persons with disabilities.
- Authority Requests: Supply documentation upon request in either paper or accessible electronic formats.
- Responsibility for Ongoing Compliance: Maintain internal documentation reflecting compliance and update it as service delivery evolves.
Technical Accessibility Requirements for Banking Services
Banking services must comply with the functional accessibility requirements laid out in Annex I. These requirements affect the design and delivery of services, including interfaces such as websites, mobile apps, ATMs, customer service portals, and contractual communications.
Annex I – Key Accessibility Principles:
Note in the bullets that follow we’ve bolded perceive(able), operable, understandable, and robust which form the acronym POUR which represents the four WCAG principles for web accessibility.
- Information, including text, images, and sounds, necessary for using the service shall be presented to users in ways they can perceive.
- User interface components and navigation must be operable.
- Information must be understandable.
- Content shall be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies.
Functional Requirements Summary:
- Perceivability: Ensure that all necessary service information—such as terms, transactions, or updates—is perceivable by users, including those using screen readers or alternative formats.
- Operability: Make sure interfaces like websites, apps, and kiosks can be navigated using keyboard-only input and support other assistive technologies.
- Understandability: Communicate instructions, input requirements, and transaction confirmations clearly and in plain language.
- Robustness: Develop services using technologies that are compatible with a range of user agents, including assistive tools such as screen readers and magnifiers.
Scope of Banking Services Under the Directive
The Directive explicitly includes banking:
This Directive lays down accessibility requirements for the following services: … (f) banking services (Article 2(1)).
Accessibility requirements for services should apply to the way in which the services are provided to users, including the provision of information and the conclusion of contracts, the provision of help-desk services and the use of payment terminals. (Recital 17)
This means the EAA covers:
- Online banking interfaces
- In-person banking terminals (e.g., ATMs, kiosks)
- Help desks and call centers
- Banking apps
- Digital contracts and customer communications
Exemptions and Limitations
Some banking institutions may qualify for limited exemptions, but most do not:
This Directive shall not apply to microenterprises providing services. (Article 4(5))
Defined in Recital 41 as enterprises with fewer than 10 employees and turnover or balance sheet not exceeding EUR 2 million.
This exemption is unlikely to apply to most banks.
Important note: This exemption applies only to microenterprises providing services, not those dealing with products. Microenterprises dealing with products must still comply with the EAA requirements but have lighter documentation obligations under Article 14(4).
Enforcement and Deadline
The Directive requires that all obligations become enforceable on:
28 June 2025 (Article 32(2))
Banking service providers must be fully compliant by this date, and Member States are responsible for market surveillance and enforcement (Article 29).
Conclusion
Under the EAA, banking service providers have clear, non-optional responsibilities:
- Administratively, they must document, explain, and publish how they meet accessibility obligations.
- Technically, they must ensure their services are designed and delivered in conformance with Annex I accessibility standards.
If your financial institution needs help with EAA compliance, we’d love to support your EAA compliance efforts. Just send us a message and we’ll be right back with you.
