European Banking Accessibility Act (EAA 2025)

What is the European Accessibility Act (Directive (EU) 2019/882)?

The European Accessibility Act (EAA) is a European Union directive whose main objective is to improve the functioning of the internal market for accessible products and services, eliminating and preventing barriers to the free movement of these elements that may arise due to divergent national legislation on accessibility. In essence, it seeks to establish common accessibility requirements for a number of key products and services, directly benefiting people with disabilities and people with functional limitations, such as older people.

For the financial sector, this means that many of the banking services covered by the Accessibility Act will need to be designed and offered so that they can be used by the greatest possible number of people, regardless of their abilities.

Main Objectives of the EAA in Banking

The implementation of the EAA in the banking sector pursues several fundamental objectives:

• Promote Financial Inclusion: Guarantee that people with disabilities and functional limitations can manage their finances autonomously and safely.
• Eliminate Barriers: Remove existing obstacles in digital (websites, apps) and physical (ATM) banking products and services.
• Harmonize Regulations: Create a single set of accessibility rules at EU level, making it easier for companies to offer cross-border products and services and reducing market fragmentation.
• Drive Innovation: Encourage the development of technological and universal design solutions that benefit all customers.

Who is affected by the European Accessibility Act in the Financial Sector?

The directive is broad in scope and affects various actors within the financial ecosystem. Mainly, the obligations of banks according to the new European accessibility law fall on:

• Banks: Both retail and commercial that offer services to consumers.
• Credit and Financial Entities: Those that provide services covered by the directive.
• Payment Service Providers: Including the thriving fintech companies that offer alternatives to traditional banking.
• Manufacturers and Importers: Of products relevant to the sector, such as ATMs or payment terminals.

It is important to note that there are some exemptions, for example, for microenterprises that provide services, under certain conditions.

Banking Services and Products Covered by the EAA

The EAA specifies a series of products and services that must comply with the new requirements. Among the most relevant for the financial sector are:

• Consumer banking services: Includes checking accounts, savings accounts, consumer loans, mortgages.
• Websites: Both information pages and online banking platforms.
• Services based on mobile devices (Banking Apps): Applications for smartphones and tablets.
• Self-service terminals:
  • Automated Teller Machines (ATMs)
  • Payment terminals (POS)
  • Other interactive self-service terminals that provide information.
• Contracts with consumers: Pre-contractual and contractual information must be accessible.
• Electronic signature services and services that allow electronic identification.

This involves a thorough review of how these services are designed, developed and delivered to ensure they do not present barriers.

Accessibility Requirements: EN 301 549 and WCAG

To ensure a common level of accessibility, the EAA relies heavily on harmonized technical standards. The key standard is EN 301 549, which establishes functional accessibility requirements for ICT products and services. In turn, the EN 301 549 standard refers to and is very compatible with the Web Content Accessibility Guidelines (WCAG), specifically level AA, for web content and applications mobiles.

Complying with these principles and the European banking accessibility requirements derived from EN 301 549 and WCAG is essential.

Deadline: June 28, 2025

The schedule for the implementation of the EAA is clear and the most important date is just around the corner:

• National Transposition: Member States had to transpose the directive into their national legislation before June 28, 2022.
• Application of Measures: Companies, including banks and financial entities, must comply with accessibility requirements as of June 28, 2025.

There are some transitional provisions, for example for self-service terminals already in use, which may continue to be used until the end of their economic useful life, but not more than 20 years after they have been put into service. However, any new product or service placed on the market after June 28, 2025 must be fully compliant. The EAA bank compliance deadlines are, therefore, a critical factor.

Specific Obligations for Banks and Financial Entities

In addition to ensuring that their products and services are accessible, banks have other obligations:

• Conformity Assessment: They must evaluate whether their products and services comply with accessibility requirements.
• Technical Documentation: Maintain technical documentation that demonstrates conformity.
• EU Declaration of Conformity: Prepare and sign an EU declaration of conformity for the products.
• Information to Users: Provide information about the accessibility characteristics of products and services.
• Complaint Handling: Establish procedures to deal with complaints regarding non-compliance.
• Cooperation with Authorities: Collaborate with market surveillance authorities.

Consequences of Non-Compliance

Ignoring EAA mandates is not an option. Failure to comply may result in:

• Economic Sanctions: Member States must establish effective, proportionate and dissuasive sanctions. These can be significant.
• Reputational Damage: The lack of accessibility can generate a negative image of the entity, alienating current and potential clients.
• Loss of Market Opportunities: Excluding part of the population limits growth.
• Possible Litigation: Increases the risk of discrimination lawsuits.

Steps for Adaptation to EAA

For banks and financial institutions to arrive prepared by June 28, 2025, it is crucial to follow a roadmap:

1. Accessibility Audit: Evaluate the current state of all covered products and services (websites, apps, ATMs, documentation, processes).
2. Strategic Planning: Develop a detailed action plan, prioritizing critical areas, assigning resources and defining those responsible.
3. Training and Awareness: Train all the teams involved (design, development, customer service, legal, marketing) in the principles and requirements of accessibility.
4. Inclusive Design and Development: Integrate accessibility from the beginning in all new projects (universal design).
5. Adaptation of Existing Systems: Make the necessary modifications to current platforms and products.
6. Comprehensive Testing: Conduct tests with real users, including people with various disabilities, and use technical validation tools.
7. Documentation and Formal Compliance: Prepare technical documentation and declarations of conformity.
8. Establish a Continuous Improvement Process: Accessibility is not a one-time project, but rather a continuous commitment.

Conclusion:

The EAA represents a significant change for the banking sector. Meeting their requirements is not only an unavoidable legal obligation with a clear deadline (June 28, 2025), but also an opportunity for banks to demonstrate their commitment to inclusion, improve the experience of all their customers and access a broader market. Adaptation requires careful planning and proactive investment, but the long-term benefits, both social and economic, are indisputable.