EAA requirements for consumer banking

In brief

Consumer banking services are in the scope of the European Accessibility Act (Article 2(2)(d)). Article 3(28) defines them as banking and financial services provided to consumers, such as payment services, payment account services and electronic money.

Beyond the general service requirements in Annex I, Section III, banks must make identification, electronic signature, security and payment services accessible, and keep information understandable.

What counts as consumer banking?

Article 3(28) lists the banking and financial services provided to consumers. They include certain credit agreements, investment services, payment services, payment account services and electronic money.

Automated teller machines are also covered, as self-service terminals under Article 2(1). See the page on EAA scope.

Requirements specific to banking (Section IV)

• Identification, electronic signatures, security and payment services must be provided in a way that is perceivable, operable, understandable and robust.
• Information must be provided in a way that is understandable, and not more complex than level B2 (upper intermediate) of the Common European Framework of Reference for Languages of the Council of Europe.

Check the exact wording of Section IV before you cite it.

Where to start in the checklist

The mapping is practical guidance, not a clause reference:

• Sign-in and identification: accessible authentication and redundant entry.
• Payments and transfers: error prevention for legal and financial data, error identification and status messages.
• Forms: labels or instructions and identify input purpose.
• Custom controls such as sliders and PIN pads: name, role, value.

Plain language and level B2

The B2 requirement is about language, not only about code. Contracts, fee tables, error messages and security prompts should use short sentences, common words and clear structure. WCAG's reading level criterion is Level AAA, so it is not in this checklist. The Directive's requirement is separate.

What to do

• Map your services. List which of your services fall under Article 3(28).
• Test identification and signing. Include biometric, OTP, app-based and card-reader steps, and offer an alternative.
• Test payments end to end. Check confirmation steps, timeouts and error messages.
• Review the language. Check key messages and terms against the B2 requirement.
• Cover ATMs and branch terminals. They are in scope as self-service terminals.

Common mistakes

• Making only the website accessible. The mobile app, ATMs and terminals are also covered.
• Relying on one security method. A method that only works with one sense or ability can lock people out. Offer an alternative.
• Treating the B2 level as optional. It is in the text of Section IV for banking information.
• Short timeouts. Security sessions that end too fast hurt people who need more time.
• Ignoring third-party providers. Identification and payment tools from partners are part of the service you provide.

Sources

• Directive (EU) 2019/882, European Accessibility Act (EUR-Lex), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.