EAA Update 1: Getting Started with the European Accessibility Act

EAA UPDATE 1
APRIL 2025
Getting Started with the European Accessibility Act (EAA):
Making bank services and financial e-commerce services more accessible

In brief This is the first edition in a series of AFM publications on the European Accessibility Act (EAA). This series is intended for all companies that must comply with this directive. This first EAA update provides an overview of what the AFM expects from these institutions by June 28, 2025 (at a minimum).

In the Netherlands, some 5.5 million people (32%) live with a disability, and in Europe, this number is 101 million (27%). From June 28, 2025, the European Accessibility Act (EAA) will enter into force. With regulations to make products and (online) services accessible to people with disabilities. The AFM has been designated as the competent authority for supervising bank services and financial e-commerce services for consumers. The AFM expects that your organization is well prepared and that steps have already been taken to be able to comply.

What does the AFM concretely expect in practice from market parties that must comply? This first EAA update provides an overview of what we (at a minimum) expect from institutions that must start complying. In our next EAA updates, we will zoom in on one or more specific themes. Here, we will align with signals from the market where possible. We expect to publish a new EAA update in the autumn. You will receive it if you are subscribed to the monthly newsletter for the sector.

1. Objective of the directive: inclusion and equal access
   The Accessibility Directive is intended to promote inclusion and equal access within the European Union. The regulations from the European directive have been incorporated into Dutch legislation, including the Financial Supervision Act and the Consumer Protection Enforcement Act. For financial institutions, this means that their (digital) services must be accessible to everyone, including people with visual, auditory, motor, or cognitive disabilities.

This requires effort, but also offers you (commercial) opportunities. For example, a larger target group can use financial services and products. Furthermore, a good customer journey helps people move faster and more successfully through your sales channels.

2. Target group: broad
   The scope of the directive is broad and applies to the majority of providers of products and services in Europe, including financial services. The AFM has been designated as the competent authority for bank services and financial e-commerce services.

• When providing 'bank services' to consumers, this involves
  offering credit agreements, investment services/ activities and ancillary services, payment services, electronic money, and services related to payment accounts.
• The provision of 'financial e-commerce services' to consumers
  is broadly about offering financial services via the internet, at individual request and with the aim of concluding an agreement.

EAA Update 1 2
EAA UPDATE 1
Examples of organizations that must comply include (large) banks and insurers, but also enterprises that only offer digital services, such as BNPL (Buy Now, Pay Later) and neobrokers. Also (larger) investment enterprises, online platforms such as crowdfunding platforms, and (larger) chains that sell mortgages may fall under the EAA.

3. What the AFM expects from you by June 28, 2025
   Your organization is well prepared for the European Accessibility Act

• You know the regulations from the law.
• You have conducted a gap analysis on what steps are needed
  to comply.
• You are building (further) expertise on digital accessibility and
  ensuring that knowledge is embedded in your organization.
• You are collecting information on bottlenecks.

Your organization ensures that (digital) services are accessible

• Your online environment is robust, operable, understandable, and
  perceivable (WCAG).
• You comply with other requirements, such as the notification obligation and placing
  an information document on your website.

Your organization ensures compliance with the Accessibility Directive

• You have policy to ensure that services remain continuously
  accessible.
• You monitor the execution of processes within your organization.
• You evaluate to determine whether the measures taken have the intended
  effect.

4. What does the AFM do?
   We are in continuous consultation with other national and inter- national EAA supervisors, with the aim of a consistent inter- pretation of the standards and a level playing field within Europe. Additionally, we provide market parties guidance on topics that raise questions and we set up a reporting point for market parties and consumers.

More explanation about the requirements of the European Accessibility Act/European Accessibility Act can be found on our theme page 'Accessibility (digital) services'.

Missing information on the theme page or do you have specific parts you are running into? You can report this by emailing:
AccessibilityDirective@afm.nl. Because we expect many questions, we cannot answer all of them individually. We use your questions to map out the most important bottlenecks. The AFM will then provide clarification as best as possible by further supplementing the information on the theme page.