Accessibility of (digital) financial services

When providing a service (in an online environment), information about the accessibility of the service must be provided and explained, including:

• How the service works
• How the service interacts with related products
• In what ways the service is accessible
• Which assistive devices can be used to operate the service

In short, the following requirements apply:

The information must be provided in at least two sensory modalities, for example through both text and audio.

The information must (also) be available in text format (e.g., HTML), so that it can be read aloud by assistive software and users can, for example, adjust the font themselves.

The information must be perceivable by all users. For instance, by adding subtitles to videos for people who are hard of hearing, and audio descriptions for people with visual impairments.

An alternative must be offered for content that is solely visual or auditory—for example, descriptive text for images or charts.

The information must be presented in a clear and understandable way, which includes showing it in a logical sequence and a predictable manner.

The information must be presented with sufficient contrast and in a font size appropriate for the conditions of use (as large as necessary).

The information must allow for adjustable letter spacing, line spacing, and paragraph spacing.

In addition, service providers must ensure the availability of support services (such as help desks, call centers, or technical support) that—when available—can provide information on the accessibility of the service and the assistive devices with which it is compatible, using accessible communication methods.

Important: Offer a range of contact options. For example, phone calls may not be suitable for people who are deaf or hard of hearing, while email may be difficult for individuals with cognitive disabilities.

 

For banking services, the following additional requirements apply:

• Providing identification methods, electronic signatures, security, and payment services which are perceivable, operable, understandable and robust;
• Ensuring 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

For (financial) e-commerce services, the following additional requirements apply:

• Providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator;
• Ensuring the accessibility of the functionality for identification, security and payment when delivered as part of a service instead of a product by making it perceivable, operable, understandable and robust;
• Providing identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust.

 

Yes, all service providers that offer banking and e-commerce services to consumers are required to prepare an accessibility statement. In the general terms and conditions, or in an equivalent document, service providers must present, in an accessible manner, information about the service’s compliance with the accessibility requirements. In summary, this information must include:

• A general description of the service and how it works;
• A description of how the service complies with the accessibility requirements;
• A description of the processes in place to ensure the service remains accessible.

When changes occur within your organization or to the applicable standards, it is essential to ensure that your (online) services remain accessible. This requires an organization-wide approach. Service providers must establish procedures that ensure continued compliance of the services with the applicable accessibility requirements. They must also train staff in the use of accessible services and, where relevant, products. The training should cover, among other things, information provision, customer advice, and marketing.

Yes, there are exceptions or exemptions in the following cases:

Micro-enterprises
Micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total not exceeding EUR 2 million are exempt from the requirements. Despite this exemption, the AFM encourages all micro-enterprises to provide services that comply with the accessibility requirements of the EAA as much as possible, in order to increase their competitiveness and growth potential within the internal market.

Disproportionate burden and fundamental alteration
The accessibility requirements do not apply if compliance would impose a disproportionate burden on the service provider, or result in a fundamental alteration to the essential nature of the service.

A service provider may invoke a disproportionate burden when the costs of compliance are not proportionate to the benefits for persons with disabilities. When assessing whether the accessibility requirements impose a disproportionate burden, only legitimate reasons may be considered. Lack of priority, time, or knowledge does not constitute a legitimate reason. Annex VI of the EAA sets out the criteria for assessing disproportionate burden. Service providers invoking this exemption must still comply with the accessibility requirements to the extent that they do not constitute a disproportionate burden. A service provider can invoke a fundamental change when compliance with accessibility rules modifies a service so radically that it results in a fundamentally different service. Service providers that receive funding from external sources, whether public or private, to improve accessibility, cannot claim a disproportionate burden or fundamental alteration.

Business-to-business (B2B)
The EAA does not apply to business-to-business services.

Supervision of the EAA accessibility requirements in the Netherlands is devided among the Authority for Consumers and Markets (ACM), the Digital Infrastructure Inspectorate (RDI), the Dutch Media Authority (CvdM), the Human Environment and Transport Inspectorate (ILT), and the Dutch Authority for the Financial Markets (AFM). For more information, visit the accessibility monitoring website of the Ministry of Health, Welfare and Sport (VWS).

Yes, if physical products are used when providing services, those products must also comply with the EAA accessibility requirements. Examples include devices such as random readers or e-dentifiers used in payment services. There is a five-year transition period for products used in the provision of a service. Services may be provided during this transition period using the products placed on the market before June 28, 2030. These products must be modified to comply with the EAA requirements during the transition period, and any replacement products must already meet the accessibility requirements.

There is a transition period for services and products used in providing the service.

It follows from the accessibility directive that service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date. However, for new contracts and for contracts that are modified (for example, when general terms and conditions are changed) from June 28, 2025, the service provider must comply with accessibility obligations. This applies to both banking services and financial e-commerce services. The accessibility of products used in providing a service is subject to a five-year transition period. These are physical products, such as a bank card and a device for logging into the bank. Services may be provided during this transition period using products placed on the market before June 28, 2030. During the transition period, these products must be upgraded or replaced to meet the accessibility requirements.

In cases where it is mandatory to provide information via a durable medium, and this is done via a pdf, then the pdf file must also be accessible. Consumers must be able to fall back on information that cannot simply be altered. Every consumer must be able to download and save this document. If a company claims disproportionate burden, and the information does not require a durable medium, an accessible alternative in HTML text on the website is sufficient, and the pdf need not be accessible.

The AFM assumes that all information that customers need to use the service must be accessible, including customer agreements and e-mail traffic. After all, if a customer can enter a contract but cannot read the confirmation email, the customer still cannot use the service independently.

In principle, a second pillar pension plan does not fall within the scope because this contract is entered into by the employer and not the consumer. There are conceivable situations in which information does need to meet accessibility requirements. In case a consumer makes their own pension choices that lead to a new agreement, this may well fall within the scope. This is very case-specific, so it is important that companies assess for themselves whether this is the case. In addition, the AFM believes it is highly desirable that information about a pension plan that does not fall within the scope is also accessible, so that consumers with disabilities can access it independently. The AFM therefore calls on companies to make information about pension plans accessible, also in cases where it does not fall under the EAA.

The provision of services to consumers must be accessible. Services to business customers are not required to be accessible. Regarding investing, consumers can request to be designated as professional investors. As a result, professional investors are not automatically business customers. In case a consumer is designated as a professional investor, investment services to those consumers must also be accessible.

Accessibility requirements apply to banking and financial e-commerce services provided to consumers. A consumer is a natural person not acting in the exercise of a profession or business. A self-employed person also deserves protection as a consumer when they conclude a financial service agreement but not in the practice of their business or profession. An example is taking out disability insurance.