- in United States
- within Technology topic(s)
- Introduction
Financial institutions have long treated accessibility primarily as a usability or customer experience topic. Websites and apps were adapted to reach broader customer groups, typically as part of design or marketing initiatives. From its application date onward, some financial services may no longer be offered to consumers unless they can be used independently by persons with disabilities. The European Accessibility Act (EAA) changes this fundamentally: accessibility becomes a legal condition for offering certain consumer services.
The main challenge for institutions is therefore not the existence of accessibility requirements, but the misunderstanding of their scope. The EAA is often perceived as a technical IT project. In reality, it affects how financial services are structured, explained and provided.
- Why Financial Institutions Are Affected
Modern financial services rely heavily on digital interaction. Account access, payments, investment services and credit applications increasingly take place through online interfaces, mobile apps and self-service terminals. The EAA targets precisely these types of consumer-facing services.
The Act does not primarily regulate financial products or contractual terms. Instead, it regulates how consumers access and use them. A service may therefore be fully compliant with financial regulatory requirements and still be unlawful if customers cannot realistically use it. For example, a payment application may meet all authentication and security requirements but still violate the EAA if visually impaired users cannot independently confirm a transaction. Accessibility thus becomes part of regulatory compliance rather than a purely technical or product-development matter. The EAA regulates the lawful usability of the service, not the permissibility of the product itself.
- A Frequent Misunderstanding
Institutions often assume accessibility mainly concerns website design standards or interface adjustments and delegate responsibility almost exclusively to IT or UX teams. This approach is insufficient.
The EAA requires that consumers can understand, navigate and complete a service journey independently. Accessibility therefore concerns communication, explanations and process structure as much as software. A credit application that requires reading dense information on a small screen without alternative formats may render the service non-compliant even if the system functions perfectly. Likewise, authentication procedures or verification steps may be non-compliant if they depend on abilities not available to all users.
The legal question is therefore not whether the system works, but whether a consumer with disabilities can complete the service journey without external assistance.
- Practical Consequences
The main impact of the EAA lies in operational processes rather than documentation. Financial institutions must ensure that consumers can obtain information about a service, understand how it works and complete the transaction independently. This obligation extends across the entire lifecycle of the service, including ongoing account access, payments or contract management.
Importantly, the Act does not generally require rewriting contractual terms. Instead, institutions must provide accessible explanations alongside existing documentation. A complex investment product may retain its standard legal wording, but the institution must explain its functioning and risks in a way that is accessible to consumers.
- A Compliance Topic, Not Just an IT Project
Because accessibility determines whether a service may be offered at all, responsibility cannot remain solely within technical departments. The EAA creates a compliance obligation comparable to consumer information requirements. Non-compliance may ultimately lead to supervisory intervention or restrictions on offering the affected service, including orders by market surveillance authorities to modify or withdraw services from the market.
Accessibility therefore becomes a governance issue requiring coordination between legal, compliance, product and technology functions. Institutions that approach accessibility only as a technical retrofit risk discovering that entire service processes must be redesigned.
- A Practical Approach
A useful starting point is not technical standards but the consumer journey. Institutions should first identify affected services and analyze whether customers with different abilities can realistically understand and complete the process independently. Only then should legal requirements be translated into operational steps and implemented technically.
This sequence is crucial: accessibility is primarily about legally usable services, not coding compliance.
- Conclusion
The European Accessibility Act ultimately introduces a product-compliance logic into consumer financial services. A service that cannot be independently used by persons with disabilities is not merely poorly designed — it may not lawfully be offered. Institutions should therefore assess accessibility before market launch in the same way they assess consumer-protection or disclosure requirements. Accessibility cannot be achieved through isolated technical adjustments but must be embedded in service design, governance structures and ongoing compliance monitoring.
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.
