Digital accessibility is no longer a side issue
The Netherlands Authority for the Financial Markets has once again reminded financial undertakings of their responsibility regarding digital accessibility. Since the European Accessibility Act enters into force on 28 June 2025, banks, insurers, credit providers, pension administrators, investment firms, and other financial service providers must ensure that their digital services are accessible to everyone.
That means: websites, apps, customer portals, documents, and digital processes must be usable for people with disabilities. Not as an extra service, but as a legal obligation.
In the third EAA update, the AFM makes it clear that it is scrutinizing more closely the way in which financial institutions demonstrate, ensure, and improve digital accessibility. The regulator also announces a compliance investigation into the digital accessibility of financial institutions.
Do you want to know exactly what the AFM expects? Then download the third EAA update from the AFM.
What does the AFM hold financial institutions accountable for?
The AFM observes that many organizations are taking steps, but also notes that the substantiation is often still insufficiently concrete. Problems arise particularly with reports of non-conformity.
A notification such as “our website does not yet fully comply with accessibility requirements” is not specific enough. The AFM wants to know which part of the service does not comply, on which function or page the problem occurs, which WCAG criteria are affected, and what measures are being taken.
For financial organizations, this means that digital accessibility must not only be resolved technically but also be demonstrably administrative. The question is therefore not only: “Is our website accessible?” The question is also: “Can we explain how we structurally monitor accessibility?”
Three points stand out
1. Non-conformity notifications must be more concrete
Financial undertakings are required to report to the AFM when their services do not yet comply with the EAA. The AFM notes that many reports are too general.
A good report specifically states:
• which trade name, service, or customer environment is involved;
• which website, app, page, function, or document flow does not comply;
• which WCAG criterion is affected;
• what the impact is for users;
• which temporary solution is available;
• which improvement measures are planned;
• when recovery is expected.
Anyone who reports too vaguely runs the risk that the AFM will be unable to sufficiently assess what is going on. This can have consequences for supervision.
2. A physical office is not an equivalent alternative
Some financial institutions offer customers with disabilities the alternative of visiting a physical branch if a digital environment is not functioning properly. The AFM clarifies that this is not an equivalent alternative.
An alternative must be genuinely usable, accessible, and equivalent for the customer. A customer who cannot perform a digital action independently must not be forced to rely on a solution that causes extra travel time, dependency, or barriers.
Think instead of an accessible digital channel, an easily reachable alternative point of contact, or a process that is handled with the same priority and quality as the original digital route.
3. The AFM examines critical WCAG criteria
In the compliance investigation, the AFM pays extra attention to fundamental WCAG criteria. These are criteria where an error can have immediate and major consequences for specific user groups.
The four critical criteria are:
WCAG 1.4.2 – Sound control
Sound that starts automatically and lasts longer than three seconds must be able to be stopped, paused, or have its volume adjusted by the user.
WCAG 2.1.2 – No keyboard trap
Users navigating without a mouse must not get stuck anywhere. They must always be able to continue navigating using the keyboard.
WCAG 2.2.2 – Pause, Stop, Hide
Moving, blinking, or scrolling content must be able to be paused, stopped, or hidden if it starts automatically and lasts longer than five seconds.
WCAG 2.3.1 – Three flashes or below threshold
Content must not flash in such a way that it poses a risk to people with photosensitive epilepsy.These criteria are fundamental. If they are not in order, a website, app, or customer environment can become completely unusable for certain users.
What does the AFM hold financial institutions accountable for?
The AFM's third EAA update is primarily a call to no longer treat accessibility as a standalone project. The regulator expects structural safeguards.
That calls for action on multiple levels.
Identify risks
Start with an up-to-date overview of your digital channels. Which websites, apps, customer portals, forms, PDFs, emails, and documents fall under your services? Which elements are critical for consumers? And where are the accessibility risks?
A WCAG audit helps to identify and prioritize the most important shortcomings.
Check your notification of non-conformity
Have you already filed a report with the AFM? If so, check whether it is specific enough. Do not just state that there are problems, but also where they are located, which criteria are affected, and how you will resolve them.
Have you not yet submitted a report, even though you know you are not yet fully compliant? Then it is advisable to address this quickly and carefully via the AFM portal.
Ensure structural safeguarding
Accessibility is not a one-time check just before going live. New content, releases, forms, documents, and campaigns can cause accessibility issues again.
Therefore, record:
• who is responsible for accessibility;
• which guidelines teams must follow;
• when checks take place;
• how findings are resolved;
• how user complaints are handled;
• how accessibility is incorporated into design, development, content, and management.
Involve people with disabilities
The AFM explicitly mentions the importance of involving people with disabilities in the design of digital services. This is logical: automated scans and technical audits are valuable, but do not always show how people actually experience a process.
User testing with people who use, for example, screen readers, keyboard navigation, or magnification software often yields immediately usable insights.
Why this is urgent
The EAA is now in force. The AFM has announced that it will investigate the state of the financial sector. Organizations that do not yet have a clear picture of their digital accessibility, or that have completed their non-conformity report too vaguely, are falling behind.
The risk is not only legal or supervisory. Digital inaccessibility directly impacts customer trust, customer experience, and independence. Particularly in the financial sector, customers must be able to conduct their business safely, independently, and without unnecessary barriers.
Need help with the next step?
Do you want to know if your digital channels, customer documents, or processes meet accessibility requirements? Or do you want to prepare for questions from regulators, compliance, or internal stakeholders?
Contact us. We are happy to help you with a practical assessment, concrete improvement steps, and an approach that structurally ensures digital accessibility.
