New Rules for the Accessibility of Products and Services

Starting from 28 June 2025, the Accessibility Directive (EAA: European Accessibility Act) will come into effect. This new European directive sets rules to improve the accessibility of products and services for people with disabilities or functional impairments. To comply, financial institutions will need to adjust their websites, establish procedures, revise information, and update their terms and conditions. Failure to meet these requirements triggers a mandatory notification to the AFM. This article explains which rules will apply and to whom.

Background

Since 2016, the UN Convention on the Rights of Persons with Disabilities has been in force in the Netherlands. This convention outlines what the Netherlands must do to improve the position of people with disabilities. The Netherlands Institute for Human Rights monitors compliance with the convention. The Dutch government encourages organisations to ensure that people with disabilities can participate fully in society. The Accessibility Directive stems from this UN convention.

Supervisory authorities are also paying increasing attention to accessibility in financial services. For example, the Dutch Authority for the Financial Markets (AFM) published a report urging the financial sector to improve access to financial services. The Dutch Central Bank (DNB) also published a study on digital payment systems, noting that one in six Dutch citizens struggles with digital payments, increasing the risk of social exclusion. DNB expects banks to maintain accessibility in payment systems and is engaging with the sector on this topic.

Industry associations such as the NVB and the Dutch Payments Association have also launched initiatives to improve payment accessibility for consumers. Member banks are helping customers who face difficulties with digital services.

Scope

The accessibility rules have a broad scope and apply to most providers of products and services across Europe. In the financial sector, both banking services and financial e-commerce services fall within the scope. Providing ‘banking services’ to consumers includes:

• Credit agreements
• Investment services/activities and ancillary services
• Payment services
• Services related to payment accounts
• Electronic money

The accessibility requirements also apply to financial e-commerce services, meaning the provision of financial services remotely via the internet or apps to consumers.

For example, a company offering savings accounts or insurance products through its online platform must ensure accessibility.
These services must be accessible to persons with disabilities—those with long-term physical, mental, intellectual, or sensory impairments who may face barriers in fully and effectively participating in society.

Exemptions

Micro-enterprises are exempt from the accessibility requirements. These are companies with fewer than 10 employees and an annual turnover of no more than €2 million.

An exemption also applies if compliance would impose a disproportionate burden. However, the service provider must justify this in writing with legitimate reasons. A lack of time, priority, or expertise does not qualify as valid justification. The provider must still apply accessibility requirements that do not cause disproportionate burden and must reassess this every five years.

Another exemption is possible in cases of fundamental alteration—if complying with the requirements would change the nature of the service to such an extent that it would no longer be the same.

What do the new rules entail?

Websites, apps, and other digital tools must meet four key principles:

• Operable – The website must be easy to navigate not only with a mouse, but also with a keyboard, screen reader, or voice commands.
• Perceivable – Text size, fonts, and contrast must make content easily readable, including for people with visual impairments.
• Understandable – The platform should be intuitive to use, allowing users to find information or complete actions like applications with ease.
• Robust – The content must be reliably interpreted by various technologies such as screen readers and assistive tools.

Financial institutions must have procedures in place to ensure their services remain accessible to people with disabilities. They must provide information in plain language and through more than one sensory channel and enable electronic signing. Accessibility should also be integrated into change management and product approval processes. The specific accessibility requirements are described in the annexes of the directive.

If a financial service does not comply with the accessibility requirements, the provider must take immediate corrective action and notify the AFM of the non-conformity.

Information provided to consumers about financial services must also meet accessibility requirements. If the service involves a product (e.g. a card reader), that product must also comply. This includes making information available via multiple sensory channels, using understandable language (maximum CEFR B2 level), and offering alternative formats for non-text content.

Accessibility rules also apply to identification methods, electronic signatures, and payment services, as these are essential to completing consumer banking transactions.

Terms and Conditions

The terms and conditions must include the following:

• A general description of the service in an accessible format
• An explanation of how the service works
• A description of how the service meets the applicable Annex I accessibility requirements
• This information must remain available as long as the service is offered

Entry into Force and Notification Requirements

The accessibility rules take effect on 28 June 2025. From that date, you must comply with the above requirements. If not, you are required to notify the AFM. This also applies if you wish to invoke the disproportionate burden or fundamental alteration exemptions.

The AFM has recently published an update on the reporting process. It identifies four levels of impact on consumers: critical, serious, moderate, and minor. The level of impact determines the reporting deadline.

In all cases, financial institutions must take immediate corrective action. If that’s not possible, the following deadlines apply:

• ‘Critical’ or ‘serious’ impact: report within one week of identification
• ‘Moderate’ or ‘minor’ impact: report within one month of identification
• Exemption requests must be submitted within one week of completing the assessment

Transitional Period

There is a transition period for products and services already in use when providing the service.

This means service agreements signed before 28 June 2025 may continue unchanged until their expiry, but no later than 28 June 2030. However, new or amended agreements and updated terms and conditions must comply with the accessibility rules from 28 June 2025 onwards. This applies to both banking services and financial e-commerce services.

If your services include a physical product, such as a bank card or login scanner, a five-year transition period applies for those products to meet the new requirements.

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