EAA: Accessibility is lasting part of serving the customer’s best interests

Call to action: assess whether you need to comply

The EAA has a broad scope. Providers of banking services and financial e-commerce services to consumers are required to comply. Examples include crypto platforms offering electronic money and online insurance providers. The AFM expects institutions to assess whether their services qualify as banking and/or financial e-commerce services under the EAA. We encourage all institutions to make their services accessible, even if they are not legally required to do so.

Our observations from an exploratory study

Organisations that are well advanced in implementation often have a clear vision of accessibility. By designating accessibility as a strategic KPI, it becomes a structural part of business operations and keeps customer interests central. Institutions that treat the EAA as a change project tend to make faster progress. It is also important to involve outsourcing partners early and make agreements on necessary adjustments. A gap analysis helps institutions take these steps. Even organisations that have made progress can improve further by using the right expertise and tools for continuous monitoring.

Safeguard customer interests in the long term

Although many institutions approach the EAA as a change project, it is important to also think about long-term embedding and internal support. Many have made good progress in terms of compliance and strategy, but integration into decision-making processes is lagging. This makes it difficult to safeguard accessibility as a long-term customer interest. By distinguishing between the customer journey of customers with and without disabilities, institutions can better monitor whether their services are truly accessible.

Reporting obligation for institutions

Since the EAA came into force, financial institutions are required to report non-conformities. This means notifying the AFM when they do not meet the accessibility requirements (non-compliance), or when invoking an exemption such as disproportionate burden. This second EAA update provides more information on these points. The AFM’s EAA updates respond to signals from the market where possible. We expect to publish a new update in early 2026. You will receive it if you are subscribed to the monthly newsletter for the sector.

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