EAA UPDATE 3

AFM Launches Compliance Investigation and Emphasizes Importance of Clear EAA Reporting

In Brief – In this third EAA update, we address accessibility requirements, specifically the following points:

• Key WCAG attention points
• Embedding accessibility within the organization
• Upcoming compliance investigation

Additionally, we provide supplementary instructions and examples for reporting non-conformity in the AFM Portal. We request that companies follow these instructions when submitting an EAA report.

APRIL | 2026

© AFM 2026 | EAA-update 3 2

Accessibility Requirements: AFM Expectations and Upcoming Investigation

The AFM expects financial enterprises to structurally ensure digital accessibility and comply with WCAG criteria. To assess the sector's current status, we will conduct a compliance investigation into accessibility in the coming quarter.

Key WCAG Attention Points

The WCAG criteria are important guidelines for meeting accessibility requirements. We expect enterprises to prioritize Level A criteria. Among these, 4 are particularly important: the non-interference criteria:

• Audio Control (1.4.2)
• No Keyboard Trap (2.1.2)
• Pause, Stop, Hide (2.2.2)
• Three Flashes or Below Threshold (2.3.1)

If any of these criteria are not properly applied, the entire website may become unusable for certain groups of visitors. Or, in some cases, it may cause risky physical reactions. Therefore, these criteria always qualify as 'critical'.

We also expect enterprises to be able to comply with Level AA of the WCAG criteria. Furthermore, with the arrival of WCAG 2.2, new criteria become mandatory. Therefore, work towards these requirements now so that you are well prepared for future obligations.

Embedding Accessibility Within the Organization

The AFM emphasizes that accessibility is broader than just WCAG criteria. We expect enterprises to have insight into the greatest accessibility risks in their services and to have processes in place to make their websites, apps, and digital services accessible and keep them accessible. Pay attention to the following points:

• An accessibility audit helps to identify bottlenecks, risks, and violations of accessibility requirements. This provides clear visibility into problems such as low text contrast, missing alt texts, buttons or links without text, missing form labels, or inadequate keyboard navigation. An audit forms the basis for targeted improvement steps.
• Ensure structural assurance through fixed guidelines, periodic checks, and clear responsibilities. Enterprises must be able to explain how accessibility is continuously ensured and monitored. New content, updates, or functionalities can again create barriers and limit accessibility. Therefore, incorporate accessibility from the start in design and development. Additionally, it is important that there are adequate procedures to receive complaints from consumers with disabilities and to resolve them.
• Involve people with disabilities from the beginning in the development and testing of your website, app, or other online applications. This makes it immediately clear whether solutions are usable in practice (and thus fully accessible). This makes the design more effective and prevents costly and time-consuming remediation actions afterwards.

Upcoming Compliance Investigation

In the coming quarter, the AFM will conduct a compliance investigation into the digital accessibility of financial enterprises. In doing so, we will test the extent to which enterprise websites comply with WCAG criteria, with specific attention to Level A criteria. We focus on sectors and services that are most used by consumers. We will use the results to determine targeted interventions and, where necessary, address enterprises on shortcomings.

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Supplementary Instructions for a Clear EAA Report to the AFM

Financial enterprises are required to report when they do not comply with the EAA (reporting of non-conformity). It is good to see that many parties have reported to the AFM and show that they are taking steps to become more accessible. However, we notice that the reports are not always filled out concretely. We can then not properly assess what the accessibility problems are exactly and where they are located.

To clarify the EAA reports, we have included supplementary instructions below for some questions from the reporting form. We request enterprises to follow these instructions when submitting a report. The instructions can also be found on the AFM website.

Question 1: For which part of the service does this report apply?

Indicate which parts of the service do not meet the requirements. Do this, for example, as follows:

• Specify for which trade name this report applies.
• Describe not only the service, such as 'insurance' or 'mortgages', but also which component. For example, whether it concerns website(s), app(s), documents (PDF, Word file or letters), e-mails, or physical products.
• Specify the function of the web page, app, documents, e-mails, or physical products for the consumer.

Note: If the same problem applies to multiple trade names or parts of the service, this can be submitted in one report. It is important that the parts of the service affected are specified, as described above.

Example – Question 1 This report applies to the trade name 'Company B.V.' and concerns the online customer portal on the web page 'Submit Request'. It specifically concerns the function 'Upload Document' during the application process.

Question 2: In what way does your service not comply with the EAA requirements?

Indicate concretely what accessibility problems exist and where they are located. Do this, for example, by indicating which WCAG criteria are involved, or in the case of an app, whether it applies to iOS or Android.

Example – Question 2 WCAG 2.1 – criterion 2.1.1 (Keyboard – A): the 'Upload Document' button is not reachable via keyboard navigation. WCAG 2.1 – criterion 1.4.3 (Contrast – AA): text labels in the upload screen have insufficient contrast. This applies to both the website, the iOS app, and the Android app.

Question 3: How many consumers are affected by this?

Indicate the number of visitors or users of a website or app. Also consider the number of people who are not yet customers.

Example – Question 3

• The web pages receive 12,000 visitors monthly.
• In the app, approximately 3,000 users actively conclude products monthly.

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Question 4: What is the level of impact on the consumer? (critical, serious, moderate, minor)

As a guideline, the impact can be determined based on the level of the WCAG criteria. A Level A criterion has a serious or critical impact, and a Level AA criterion has a moderate or minor impact.

Example – Question 4 The impact is serious, because a Level A criterion is affected and keyboard users are hindered from completing the application independently.

Question 5: What measures are being taken to correct the non-conformity?

Indicate concretely what steps are being taken to meet the requirements and which departments within the organization are involved. For example, indicate in which processes this is included so that it is permanently ensured.

Example – Question 5

• IT department adjusts navigation, button structure, and color contrast.
• UX team tests the solution with a panel of users with visual impairments.
• Accessibility is structurally built in via a WCAG checklist in the development process.
• Solutions are rolled out within 8 weeks; Department X monitors progress.

Question 6: Are there equivalent accessible alternatives with which the service can be used (for example, an e-mail address)?

We see that enterprises, for example, indicate that customers can come to a physical office as an alternative solution. This is not an equivalent alternative for people with disabilities, as not everyone has the opportunity to come to an office.

Example – Question 6

• Customers can submit their request via our e-mail address. These e-mails are fully accessible for screen readers and are treated with the same priority as other digital requests.
• Customer service offers support when customers encounter limitations. Employees are trained to perform actions on behalf of the customer and are reachable via phone and chat.
• When a customer gets stuck, an alternative channel is offered, such as the possibility to use a phone number or e-mail address, or to switch from the app to the web environment to complete the action there.