This is part 4 (service provider) in a series of hypotheticals designed to show the steps to take for compliance with the European Accessibility Act (EAA).
Crypto Investors Exchange is a European cryptocurrency trading platform offering spot trading, derivatives, staking services, and a crypto wallet to consumers across the EU. As a provider of consumer banking services and e-commerce services, Crypto Investors Exchange must comply with comprehensive accessibility requirements now that the EAA is enforceable as of June 28, 2025.
Here’s the general path forward to compliance for Crypto Investors Exchange.
Step 1: Identify Which Services Fall Under EAA
Map your entire service portfolio against EAA definitions. For crypto exchanges, covered services under Article 2(2) include:
Consumer banking services (Article 3(28)):
- Payment services as defined in PSD2 (crypto-to-fiat conversions)
- Electronic money services (stablecoins, e-money wallets)
- Services linked to payment accounts
- Specific investment services from MiFID II Annex I Section A and B
E-commerce services:
- Online marketplace for buying/selling crypto
- Web-based trading platform
- Mobile applications
- Digital wallet services
B2B services and institutional trading platforms fall outside EAA scope.
Transitional provisions under Article 32:
- Services provided after June 28, 2025 must be fully compliant immediately
- Products used in service delivery (servers, terminals) lawfully in use before June 28, 2025 can continue until June 28, 2030
- Self-service terminals can operate until end of economic life (max 20 years)
- Service contracts signed before June 28, 2025 may continue unchanged until expiration (max 5 years)
Step 2: Understand Service Accessibility Requirements
Review Annex I requirements for services, specifically Sections III and IV:
Section III – General Requirements (All Services)
- Accessibility of products used in service provision Ensure all products integral to service delivery meet accessibility requirements.
- Information about service functioning must include:
- Description of how the service works
- Accessibility features available
- Multiple format provision (written and oral)
- Presentation methods perceivable by all users
- Text formats enabling alternative assistive formats
- Understandable presentation
- Websites and mobile applications must be:
- Perceivable: All information and UI components presented in ways users can perceive (text alternatives, captions, contrast)
- Operable: All functionality keyboard accessible, adequate time limits, no seizure risks, clear navigation
- Understandable: Readable text, predictable pages, input assistance, error identification
- Robust: Maximum compatibility with assistive technologies
- Support services (where available) must provide:
- Information on product/service accessibility
- Compatibility details with assistive technologies
- All information in accessible communication modes
Section IV – Specific Requirements for Banking Services
- Identification methods, electronic signatures, security, and payment services must be:
- Perceivable through multiple sensory channels
- Operable with various input methods
- Understandable with clear instructions
- Robust for assistive technology compatibility
- Information complexity:
- Cannot exceed level B2 (upper intermediate) of the Common European Framework of Reference for Languages
Step 3: Audit Current Platform Accessibility
Conduct comprehensive accessibility assessments of all service touchpoints:
Web platform audit:
- WCAG 2.1 AA compliance evaluation
- Keyboard navigation throughout all functions
- Screen reader compatibility testing
- Color contrast verification (4.5:1 for normal text, 3:1 for large text)
- Form accessibility and error handling
Mobile app assessment:
- Native accessibility features for iOS (VoiceOver) and Android (TalkBack)
- Touch target sizing (minimum 44×44 points iOS, 48×48 dp Android)
- Gesture alternatives for all functions
- Voice control compatibility
Trading interface specifics:
- Real-time data accessible to screen readers
- Keyboard-operable trading functions
- Non-color-dependent information display
- Customizable timeout periods
- Clear confirmation dialogs
Security feature review:
- Multiple 2FA method options
- Accessible CAPTCHA alternatives
- Biometric authentication alternatives
- Clear security notifications
Step 4: Implement Platform Modifications
Based on audit findings, implement required changes:
Authentication improvements:
- Provide at least three 2FA methods (SMS, authenticator app, email)
- Implement accessible CAPTCHA alternatives (audio challenges, logical questions)
- Allow extended session timeouts with user control
- Provide clear, specific error messages
Trading interface updates:
- Enable complete keyboard control for all trading functions
- Implement screen reader announcements for price changes
- Provide high contrast mode and customizable color schemes
- Create simplified view option with essential information only
- Ensure order confirmations are fully accessible
Documentation accessibility:
- Provide all documents in HTML format (primary)
- Offer alternative formats (PDF/A, audio) on request
- Use plain language summaries for complex terms
- Include text descriptions for all visual content
Step 5: Prepare Compliance Documentation
Create required documentation per Article 13 and Annex V:
Service accessibility information must include:
- How each service feature meets accessibility requirements
- Known limitations and available alternatives
- Compatibility information with specific assistive technologies
- Contact information for accessibility support
Documentation requirements:
- Available in written format (accessible HTML/PDF)
- Available in oral format (audio/video with captions)
- Publicly available throughout service operation
- Regular updates when services change
Implementation approach:
- Create dedicated accessibility portal
- Integrate information into help documentation
- Train customer service on accessibility features
- Provide in all EU languages where service operates
Step 6: Establish Monitoring and Feedback Systems
Implement ongoing compliance procedures per Article 13(3):
Internal procedures:
- Monthly accessibility testing schedule
- Pre-release accessibility review for all updates
- Automated accessibility monitoring tools
- Regular staff training updates
Customer feedback mechanisms:
- Dedicated accessibility feedback channel
- 48-hour response commitment
- Issue tracking system with priority levels
- Quarterly public reports on improvements
Compliance tracking:
- Document all accessibility tests and results
- Track customer complaints and resolutions
- Monitor assistive technology compatibility
- Review emerging accessibility standards
Step 7: Ensure Products Used in Service Delivery Comply
Verify all products integral to service delivery meet requirements:
Hardware assessment:
- Crypto ATMs or kiosks must meet self-service terminal requirements
- Payment terminals for partnerships must be accessible
- Any customer-facing hardware must comply
Software components:
- Third-party payment processors must provide accessible interfaces
- KYC/AML services must offer accessible verification methods
- Trading engines must support accessibility APIs
- All integrated services must maintain accessibility
Vendor management:
- Include accessibility requirements in all contracts
- Verify vendor compliance documentation
- Maintain alternative accessible options
- Conduct regular vendor accessibility audits
Step 8: Prepare for Compliance Verification
Establish procedures for authority interactions per Article 23:
Documentation readiness:
- Centralized compliance documentation repository
- All accessibility test results and remediation records
- User feedback summaries and response logs
- Vendor compliance certifications
Response procedures:
- Designated compliance officer with decision authority
- 72-hour response protocol for authority requests
- Translation capabilities for all EU languages
- Escalation procedures for complex issues
Ongoing compliance demonstration:
- Quarterly internal audit reports
- Annual third-party accessibility assessments
- Continuous monitoring dashboards
- Regular updates to authorities on improvements
Conclusion
EAA compliance for crypto exchanges requires comprehensive accessibility implementation across all consumer-facing services. Services must be fully accessible immediately, while products used in service delivery benefit from transitional provisions. Success requires integrating accessibility into all development processes, maintaining thorough documentation, and establishing robust monitoring systems.
Working with accessibility and compliance experts like Accessible.org helps ensure an efficient and effective path to EAA compliance.
Legal Disclaimer: This post represents our interpretation and analysis of the European Accessibility Act (EAA) and related accessibility requirements and obligations but does not constitute legal advice. While we strive for accuracy, Directives and their interpretation may vary by EU member state and change over time. Consult with legal counsel regarding your specific situation.
