The European Accessibility Act and Banking: What EU Financial Institutions Need to Know

The European Accessibility Act (EAA) is set to reshape how banks deliver digital services to customers across the European Union (EU). As enforcement begins, financial institutions that have not already achieved compliance must take urgent steps to meet accessibility standards.

While finance has steadily digitized over the past decade, many web and mobile banking experiences remain difficult—or impossible—for people with disabilities to use. The EAA aims to change that by requiring that banking services used by consumers, such as apps, self-service kiosks, and ATMs, are designed and built accessibly. (The EAA also mandates accessibility for a wide range of other consumer products and services, including e-commerce and transportation.)

This article will break down what EAA compliance involves in banking, and what’s at stake for businesses that don’t meet the law’s requirements. We’ll also highlight the rewards of accessibility for banks, financial institutions, and their vendors, and outline best practices to help you get started aligning with compliance standards. For more in-depth guidance, you can explore our Complete Guide to EAA Compliance.

How the EAA applies to banking in the EU

The EAA sets harmonized accessibility requirements across all EU Member States for key consumer-facing technologies. For banks, this means that many common digital and physical customer touchpoints must be perceivable, operable, understandable, and robust (POUR) for users with disabilities. The best way for banks to demonstrate that they meet the EAA’s requirements is through conformance with EN 301 549, the European standard for information and communications technology (ICT) accessibility.

Banking experiences covered by the EAA include:

• Online banking websites and mobile apps.
• Customer portals and digital onboarding systems.
• ATMs and self-service kiosks.
• Payment terminals and authentication devices.
• Digital communication channels, such as support services, chatbots and secure messaging platforms.

In short, any product or service that enables a consumer to manage their finances, open an account, transfer funds, or communicate with their bank must be accessible under the EAA.

The EAA applies to all banks operating within the EU, regardless of where they’re headquartered. Additionally, the law’s requirements extend to third-party technology that’s integrated into consumer banking services. So even if your customer support chatbot or mobile app is built by a vendor, your institution remains responsible for ensuring it meets EAA standards.

What’s at stake for banks?

Failing to meet EAA compliance requirements can expose your institution to serious financial and reputational risks.

• Penalties: Each EU Member State has established its own mechanisms for enforcing the EAA. In many countries, penalties include steep fines and market bans.
• Reputational damage: Accessibility gaps can lead to public scrutiny, especially for institutions that serve large or diverse customer bases. In today’s social climate, consumers and investors expect banks to meet high standards for equity and inclusion.
• Lost customers: Poor accessibility can drive away customers with disabilities or aging populations, limiting revenue.

The upside of accessible banking services

The EAA doesn’t just introduce regulatory pressure—it also creates opportunities for innovation and growth. Banks that treat accessibility as a strategic priority can realize major benefits:

• Stronger customer loyalty: Accessibility improves user experience for all customers, including those with temporary disabilities and those who are aging.
• Broader market reach: One in four adults in the EU lives with a disability. Making banking services accessible opens your business to a historically underserved customer segment.
• Reduced operational costs: Proactively embedding accessibility into development cycles reduces the need for costly retrofitting, accelerates release timelines, and simplifies procurement.
• Alignment with ESG and CSR goals: Accessibility is an increasingly important metric in environmental, social, and governance (ESG) reporting and corporate social responsibility (CSR) initiatives.

Getting started with EAA compliance in banking

At first, EAA compliance can feel complicated, especially for banks managing large portfolios of websites, apps, and digital documents. And achieving full conformance with EN 301 549 won’t happen overnight. However, taking the following steps will help you get started improving digital accessibility and mitigating your risk of regulatory enforcement action.

1. Create an action plan.

Take stock of your bank’s digital experiences to understand the full scope of assets covered by the EAA. Remember that web accessibility is just one part of EAA compliance in banking: Banks must also ensure that mobile apps, digital documents, and ATMs are usable by people with a range of disabilities.

Next, develop a plan for bringing these assets into compliance. Your plan should include who within your organization will be accountable for digital accessibility, who will be involved, and the tools and resources they’ll use to perform this work.

If your organization has a large collection of digital assets covered by the EAA, you’ll also need to decide which assets you’ll focus on making accessible first. To minimize risk, organizations often choose to prioritize assets with the highest visibility, like public websites, or key user flows within their digital assets.

2. Audit your digital channels.

Engage accessibility experts to audit your highest-priority digital experiences for EN 301 549 conformance. For thorough and reliable results, audits should include manual testing with assistive technologies, in addition to automated scanning. These audits will identify any potential accessibility barriers you’ll need to address to meet EAA requirements. They’ll also provide context on which issues have the biggest impact on users and may pose the greatest compliance risks—so you know what fixes to tackle first.

3. Remediate issues and document your progress.

Once you’ve identified accessibility barriers in your products and services, it’s time to remediate these issues. This may include redesigning key interfaces, improving semantic structure in your code, or replacing inaccessible widgets.

As part of this process, document your progress. Publishing documentation about your services’ accessibility (e.g., an accessibility statement) is a requirement for EAA compliance. Additionally, documented proof that you’re making an effort to enhance accessibility may help reduce regulatory risks as you work toward full conformance with EN 301 549.

4. Build accessibility into your development life cycle.

Don’t wait until digital experiences are live to catch and address issues. Instead, embed accessibility into your product development lifecycle:

• Define the acceptance criteria for accessibility.
• Design with accessibility in mind.
• Use accessibility testing tools during development.
• Include accessibility checks in QA processes before release.

Training teams in inclusive design and development practices will ensure professionals have the skills they need to incorporate accessibility into their day-to-day workflows.

5. Establish accessibility governance.

Accessibility is not a one-time fix. Digital experiences change over time, and every new update may introduce barriers that impact your compliance status. To maintain long-term accessibility, build a governance framework that includes:

• Designated accessibility owners across teams.
• Ongoing accessibility monitoring.
• Processes for collecting and responding to accessibility feedback from users.

Beyond reducing compliance risks, a sustained commitment to accessibility will reinforce trust with your customers.

Online banking accessibility isn’t optional.

Digital accessibility is now a baseline requirement for banks across the EU. And EAA compliance is more than a regulatory obligation: It offers financial institutions a unique opportunity to innovate and open their services to a broader market.

At Level Access, we’ve spent more than 25 years helping organizations in Europe, North America, and worldwide meet their accessibility goals. Our end-to-end solution spans the three pillars of successful accessibility programs: Audit & Test, Build & Fix, and Governance & Reporting.

Whether you’re obtaining your first accessibility audit or optimizing a mature program, our team is more than willing to assist you. Contact Level Access today to learn how we can support your journey toward sustainable accessibility and compliance.

Frequently asked questions

What banking services are covered under the EAA?

The EAA applies to a wide range of consumer-facing banking services. Specifically, the EAA covers:

• Credit agreements
• Reception and transmission of orders
• Execution of orders
• Portfolio management
• Investment advice
• Safekeeping and administration of financial instruments for the accounts of clients
• Granting credits or loans
• Foreign exchange services
• Investment research and financial analysis
• Payment services
• Services linked to a payment account
• Electronic money
• Electronic signature services

Digital technologies used to provide these services, including websites, mobile apps, ATMs, digital portals, and customer communication platforms, must meet accessibility standards under the EAA.

What standard should banks follow for EAA compliance?

Banks should align their digital products and services with EN 301 549, the harmonized European standard for ICT accessibility. This standard outlines the requirements for making software, websites, hardware, and other technologies accessible to users with disabilities.