European Accessibility Act: Focus on Financial Services

From summer 2025, landmark reform of accessibility and digital inclusion will apply across the EU in a range of sectors, including the consumer banking and financial sector. The European Accessibility Act (Directive (EU) 2019/882) (the EAA) applies from 28 June 2025 in all Member States and seeks to eliminate barriers for consumers with disabilities by harmonising accessibility requirements across the internal market for certain products, services and built environments. A further objective of the EAA is to facilitate the free movement of accessible products and services within the EU’s internal market.

The EAA and banking and financial services

The EAA applies broadly to the consumer banking and financial sector for the purpose of ensuring individuals with disabilities “are adequately protected on an equal basis with other consumers” throughout the EU as follows:

1. Consumer banking services: These services include most consumer banking and financial services such as credit agreements (i.e. consumers loans and mortgages), online payment services, some investment services (including some ancillary services), other services linked to a payment account (e.g. opening a payment account), and e-money.   
2. Self-service terminals: The EAA applies to the following products (including their hardware and software): payment terminals, ATMs, ticket queuing machines and interactive self-service terminals providing information (such as interactive information screens and kiosks).
3. Built environment: Branches, facilities and other physical locations may be in-scope where the service is delivered in a Member State that implements the EAA’s optional requirements concerning the built environment. 

Accessibility requirements for the banking and financial sector

Responsibility for ensuring compliance of a consumer banking service with its accessibility requirements rests with the provider of that service. For products, the EAA imposes obligations on specific actors in the supply and distribution chain, such as the manufacturer, importer and distributor of the product. Financial firms may be directly in-scope of the EAA, but their downstream providers and suppliers of in-scope services and products may also have obligations under the EAA. 

Financial firms may be directly in-scope of the EAA, but their downstream providers and suppliers of in-scope services and products may also have obligations under the EAA, or will find their financial services clients flow down obligations to them through contracts. 

The EAA imposes general and specific accessibility requirements which vary depending on whether they relate to a service, a product (i.e. a self-service terminal) or the built environment. For example, a manufacturer of an ATM or a payment terminal must, among other requirements, ensure that it:

• supports text-to-speech technology, 
• allows for the use of personal headsets, and
• gives the possibility to extend the time limit before cancelling the transaction. 

Providers of consumer banking services, among other requirements, must:

• make websites (including online and mobile apps) making them perceivable, operable, understandable and robust so that they are easily accessible in a consistent and adequate way,
• provide identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust, and
• ensure information is understandable and does not exceed a complexity level above level B2 of the Council of Europe's Common European Framework of Reference for Languages.

Where available, support services (e.g. help desks or call centres), must also be provided for consumer banking services and self-service terminals under the EAA to provide information on the accessibility of the service or product and its compatibility with assistive technologies.

Certain facets of consumer banking services have historically posed barriers to inclusive banking. For example, a 2022 European Central Bank survey of national central banks identified strong customer authentication (which is relevant to security and identification functions listed above) as a barrier to conducting payments via electronic tools and devices for many people with disabilities. These issues may need to be taken into account when assessing conformity with accessibility requirements.

Finally, with respect to the built environment, where applicable, providers of consumer banking services must ensure that the accessibility of indoor and outdoor areas used by their consumer clients must be maximised their use in an independent manner by persons with disabilities.

Countdown to 28 June 2025: How we can help you

Given the range of services, products and facilities that the EAA will apply to for banking and financial services, firms need to take steps to assess the impact of the EAA upon their business, both on- and offline. We are currently helping a wide range of businesses in the sector and who service it in addressing their requirements, and the approach taken varies depending on their role in the supply chain, the jurisdictions in which they operate and the nature of the elements of their business that are in-scope of the EAA. We have helped clients with portfolios of products across the EU-zone to others focussed on the requirements of a single jurisdiction, product or service.

Ahead of 28 June 2025, firms and their service providers and product suppliers should:

1. Assess whether your product, service or branch/facility is in-scope and familiarise yourself with the applicable accessibility requirements to each in-scope element.
2. Identify which territories are relevant to your business and whether any additional local requirements apply through national implementing laws, such as, for example, additional financial services or the requirements concerning the built environment. 
3. Conduct a gap analysis to identify whether applicable accessibility requirements are met or whether further measures are required.
4. For firms providing any consumer banking services, prepare and publish the accessibility notice or statement, ensuring all mandatory information required by the EAA is included. 
5. Update internal policies and procedures and train appropriate staff e.g. staff members who develop or design in-scope products or services, or provide support to consumers using them. 
6. Review your vendor/service provider contracts to ensure responsibility for complying with the accessibility requirements is appropriately allocated through the supply chain.

For more information on the EAA, please see our previous articles: 

• European Accessibility Act: is it time to update your websites, products & services to meet Europe’s accessibility requirements? 
• A guide to navigating the European Accessibility Act for online retailers, service providers and platforms

If you would like further information or for help with your EAA compliance plans, please contact Deirdre Kilroy and Kelly Mackey.

Information correct as of 26 February 2025.