Regulatory Influencer: EU Accessibility Act - What Does It Really Mean?

On June 28, 2025, the European Accessibility Act (Directive (EU) 2019/882 on the accessibility requirements for products and services — EAA) became applicable across the European Union. The act covers products and services identified as most important for persons with disabilities and are most likely to have diverging accessibility requirements across EU countries. The EAA affects numerous sectors, including the banking and finance sector, with consumer banking services being highlighted in the directive. Consumer banking services include credit agreements, services linked to payment accounts and the provision of payment services under the revised Payment Services Directive (PSD2). 

The purpose of the directive is to contribute to the proper functioning of the internal market by harmonising the accessibility requirements for certain products and services set out in the laws, regulations and administrative provisions of the member states. The EAA aims to eliminate and prevent barriers to the free movement of accessible products and services arising from divergent accessibility requirements in member states.

All European Union member states have transposed the directive, with the aim of ensuring harmonised accessibility requirements across the Union.

The Bigger Picture

The EAA has been designed to harmonise the accessibility standards across the EU to make it easier for people with disabilities to access essential services and products. This 

covers a wide range of sectors, including e-commerce, telecoms, banking and payment services, passenger transport and media. The aim is to ensure that people with disabilities can fully participate in economic, social and cultural life while boosting opportunities for businesses that comply. 

To ensure the accessibility of services falling within the scope of the EAA, products used in the provision of services with which the consumer interacts are also required to comply with the applicable accessibility requirements. The framework affects operators across the supply and distribution chain of in-scope products and services.

As stated above, the EAA covers consumer banking services such as banking and payment services, which are in scope because they are central to people’s ability to manage their financial lives. It covers physical banking services such as branches and ATMs, and digital banking services such as online banking and mobile payment apps. The EAA applies to these services to ensure individuals with disabilities are “adequately protected on an equal basis with other consumers” throughout the EU.

Under the EAA, consumer banking services mean the provision to consumers of the following banking and financial services:

• Credit agreements covered by Directive 2008/48/EC (the Consumer Credit Directive) or Directive 2014/17/EU (the Mortgage Credit Directive).
• Services defined in Section A (1, 2, 4 and 5) and Section B (1, 2, 4 and 5) of Annex 1 to Directive 2014/65/EU on markets in financial instruments (MiFID II Directive).
• Payment services as defined in Article 4(3) of Directive (EU) 2015/2366 (the revised Payment Services Directive - PSD2).
• Services linked to the payment account as defined in Article 2(6) of Directive 2014/92/EU on comparability fees related to payment accounts.
• Electronic money as defined in Article 2(2) of Directive 2009/110/EC (the Electronic Money Directive).

The accessibility requirements for products and services, as set out in Section III of Annex I to the EAA (including consumer banking services), are as follows:

• Providing information about the functioning of the services, and where products are used in the provision of the service, their link to these products, as well as information about their accessibility characteristics and interoperability with assistive devices and facilities:
  • Making the information available via more than one sensory channel.
  • Presenting the information in an understandable way.
  • Presenting the information to users in ways they can perceive.
• Making websites, including related online applications and mobile device-based services, accessible consistently and adequately by making them perceivable, operable, understandable and robust.
• Having support services that provide information on the accessibility of the services and their compatibility with assistive technologies, in accessible modes of communication.

Section IV of Annex I provides additional accessibility requirements specific to consumer banking services, which are to:

• Provide identification methods, electronic signatures, security and payment services which are perceivable, operable, understandable and robust.
• Ensure that the information is understandable, without exceeding a level of complexity superior to level B2 (upper intermediate) of the Council of Europe’s Common European Framework of Reference for Languages.

The EAA also establishes accessibility requirements concerning the “built environment”, where services may be provided in addition to the accessibility requirements of services. These requirements apply to built environments in which a service is provided and is under the service provider's responsibility, where the accessibility of areas intended for public access is ensured. This requirement would cover bank branches, ATMs and the surrounding area, and other public places where services may be provided.

Why should you care?

With the EAA now in force and aiming to harmonise accessibility regulations across member states, companies within its scope can benefit from a reduced regulatory burden by no longer needing to navigate varying national requirements. As the EAA simplifies compliance, companies, including financial institutions, should have a reduced administrative burden as less time and money should be spent on possible legal consultations and localised adjustments.  

The EAA also reduces the risk of non-compliance with the clear EU-wide requirements, providing a sense of legal certainty across borders. Consistent standards and procedures across member states mean companies can rely on predictable enforcement.

However, financial institutions that provide consumer banking services should be aware that, following the entry into force of the EAA, member states are required to lay down rules on penalties applicable to infringements of national provisions adopted pursuant to the EAA and take all measures necessary to ensure that they are implemented. Non-compliance with the EAA and the national provisions adopting the provisions of the act may result in fines and penalties. 

For example, in Latvia, the Accessibility of Goods and Services Act, which transposes the EAA, gives the designated competent authority the power to monitor the compliance of services and the right to request that the service provider take necessary actions to eliminate any non-compliance within a set time limit. Meanwhile, in Portugal, Decree-Law No. 82/2022, which transposes the EAA, sets out administrative sanctions that are punishable by a fine.  

To ensure that the products and services provided are compliant with the provisions of the EAA, financial institutions should:

• Assess which of their products and services fall within the scope of the EAA.
• Conduct a gap analysis to see where their services fall short of the accessibility requirements in the annexes to the EEA.
• Identify which countries are relevant to their business and whether any additional local requirements apply.
• Employ the examples of possible solutions in Annex II of the EAA to meet the accessibility requirements, such as:
  • Making the identification dialogues on a screen readable by screen readers so that blind persons can use them.
  • Using the same work in a consistent manner or in a clear and logical structure so that persons with intellectual disabilities can better understand.
  • Providing text descriptions of pictures.
• Prepare and publish accessibility notices and statements, including all mandatory information.
• Update internal policies and procedures relating to the accessibility requirements of services on offer and train appropriate staff, including those who develop services or support customers using them.
• Ensure the development of any new services is designed with accessibility in mind, using the EAA as a guideline on technical accessibility points.

Next steps

As the EAA is now applicable across the Union, financial institutions must take proactive steps to make digital and physical services accessible to people with disabilities. This is about complying with regulations, fostering trust and inclusion, and accessing new market opportunities in an increasingly digital economy.

Institutions that act early and make accessibility a priority and not an afterthought can tap into a section of the public that has felt sidelined and underrepresented, providing products and services that truly cater to their accessibility needs. Demonstrating a commitment to inclusion and social responsibility will also improve brand reputation by strengthening public trust and customer loyalty.