1. Context, scope and timeline

To eliminate barriers created by fragmented national rules, the EAA aims to unify in a central framework accessibility requirements for products and services placed in the EU market, reducing regulatory complexities.

The EAA’s requirements will both enhance accessibility for millions of people while empowering businesses to innovate, create new opportunities and build a more inclusive future.

A. What is the EAA’s application scope?  

The EAA encompasses a wide range of products and services identified as most important for persons with disabilities. They include digital devices, communication services, transportation, and banking and e-commerce products and services.

Regarding the financial sector, both manufacturers and distributors of financial products and services offered in the EU must consider the EAA’s requirements, even if headquartered outside Europe.

While the EAA applies to any product or service offered in the EU market, the text does not directly mention business-to-business (B2B) systems and operations. In addition, differences in national transpositions and local authorities’ expectations can complicate the design of appropriate action plans.

B. When will the EAA apply?

Member States were required to transpose the directive into national laws by 28 June 2022. The EAA enters into application on 28 June 2025, with a transitional period until 28 June 2030 for services and products created before 28 June 2025.

Click here to enlarge the timeline

2. Key changes and impacts on financial services

A. What are the EAA’s key requirements? 

Under the EAA, product and service providers should consider accessibility when:

Providing information to their customers

Labeling, instructions and warnings should be available via more than one sensory channel, presented in an understandable way, and in fonts of adequate size.The provider should also ensure the information is understandable for an upper intermediate language level (Level 2 of the Council of Europe’s Common European Framework of Reference for Languages).

Designing user interfaces

The product, including its user interface, should contain features, elements and functions that allow persons with disabilities to access, perceive, operate, understand and control the product. Notifications should also be outlined via more than one sensory channel, providing alternatives to vision, auditory, speech and tactile elements.

The product should provide software and hardware for interfacing with the assistive technologies.

Designing identification methods

The service provider should consider access by people with disabilities. In other words, by providing identification methods, electronic signatures, and security and payment services that are perceivable, operable and understandable.

B. What are the potential impacts for financial service providers? 

The EEA will impact a range of B2C financial products and services, including:

• Online banking platforms;
• Investment and portfolio management services, including related reports (e.g., PRIIPs KID);
• Credit filing digital processes;
• Credit and payment cards;
• Onboarding processes and editable PDF forms;
• Client communication and information (e.g., corporate action notification and reporting); and
• Proxy and voting services.
  

Therefore, all businesses in scope of the EAA, including banking services and ATM providers, should assess the overall accessibility of their current setup, considering measures like:

• Improving accessibility for screen reader users;
• Providing text alternatives for relevant images;
• Ensuring keyboard navigation works seamlessly;
• Allowing a consistent navigation;
• Providing accessible error messages; and
• Offering support via multiple channels, including live chat and support for assistive technologies.

3. Getting started with digital accessibility compliance under the EAA

Accessibility is a recognized innovation driver, encouraging the development of technologies that benefit all users like text-to-speech, real-time text, and voice interaction. Companies already aligned with certain standards, such as the Web Content Accessibility Guidelines (WCAG) 2.2 or ISO/IEC 30071-1:2019, are more likely to meet the EAA’s requirements more efficiently.

For others, these standards may offer a helpful starting point, provide valuable guidance and support their journey toward compliance and inclusivity.

To make their digital interfaces accessible, companies should:

• Conduct an accessibility audit: start by assessing their digital interfaces’ current accessibility level using automated tools or experts.
• Train teams: educate development, content and design teams about accessibility standards and best practices.
• Implement accessibility design practices: key actions include ensuring color contrast, responsive designs, text alternatives and navigable interfaces. To go further, they should consider forming a unified user experience (UX) design team and a robust design system.
• Involve users with disabilities: test interfaces with real users with disabilities and implement a feedback system for improvements.
• Regular monitoring and updates: regularly review and revise digital interfaces to stay compliant.
  

Following these steps can help companies move toward EAA compliance and ensure accessibility for all users. Emerging technologies like artificial intelligence (AI) could create new opportunities for inclusivity, by enhancing digital interfaces with adaptive features, real-time translations and personalized support.

The journey toward accessibility is ongoing. By embracing evolving technologies, companies can stay at the forefront of inclusive design, ensuring a more accessible and equitable digital landscape for all. With the right tools and mindset, organizations can build a future that benefits everyone.

4. Beyond compliance: A gateway to innovation and inclusivity

The EAA serves as a powerful catalyst for growth and innovation, enabling businesses to unlock new markets, enhance customer experiences and strengthen their competitive edge in a rapidly evolving digital landscape. Embracing accessibility not only drives innovation, but also positions companies as forward-thinking and socially responsible, bolstering their brand image and expanding market reach.

Nearly one in seven people live with disabilities in Luxembourg, representing a significant and influential consumer segment.¹ By embracing accessibility, businesses can connect with this overlooked market, gaining a competitive edge over companies that overlook accessibility standards.

Complying with the EAA enhances UX for everyone. Implementing accessibility features not only benefits users with disabilities but also contributes to a more user-friendly design overall, including straightforward navigation on websites, mobile applications and digital platforms, accessible search functions, and readable text. Businesses that prioritize accessibility can boost customer satisfaction and loyalty, building a positive brand reputation rooted in inclusivity.

In a nutshell, the EAA is not merely a regulatory mandate but a tactical opportunity for businesses to grow into a new market segment, broaden their inclusivity strategy and encourage innovation. By seizing this chance to enhance the accessibility of their products and services, companies can go beyond compliance to foster a cultural shift that expands their sustainable ambitions and contribution to society.
 

For any questions or support in your journey towards increasing the reach of your product and services, please contact us below.

¹ Statec, Nearly one person in seven feels disabled in Luxembourg, March 2024.

This article was written in collaboration with our Deloitte experts:

• Astrid Brandy – Regulatory Lead
• Eleonora Belenghi – Subject Matter Expert
• Giorgio Consoli – CoE Sustainability Regulatory Hub