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News 23/04/26

Ensure clear accountability for safeguarding and monitoring digital accessibility

Financial institutions are working to make their digital services accessible. This is important, because it ensures that people with disabilities can manage their finances independently. To provide further guidance to the sector, the Autoriteit Financiële Markten (AFM) shares expectations and points of attention in the third EAA update. In the coming months, we will conduct a compliance review on accessibility. We encourage the sector to further refine their notifications of non compliance.


In short

  • AFM expectation: identify accessibility risks and embed compliance in internal processes
  • Clear EAA notifications: essential for your service provision and for the AFM’s supervision
  • We are conducting a compliance review on the accessibility of the sector

AFM expectation: identify accessibility risks and embed compliance in internal processes

The WCAG criteria provide important guidance for compliance with the European Accessibility Act (EAA). This international standard for the accessibility of websites, apps, and digital documents consists of three conformance levels: A (minimum), AA, and AAA (maximum). These levels determine how accessible a website is for people with disabilities. The EAA requires companies to comply with both level A and level AA. We expect financial institutions to have insight into the accessibility risks within their services and to implement improvements that comply with the required WCAG criteria. They should also have processes in place to embed and monitor the accessibility of their websites, apps, and digital services. In our third EAA update, we provide practical points of attention, such as involving people with disabilities early in the design of digital services.

Clear EAA notifications: essential for your service provision and for the AFM’s supervision

Financial institutions are obligated to notify the AFM when they don’t comply with the EAA (notification of non-compliance). We are pleased to see that many institutions have submitted a notification to the AFM and demonstrate that they are taking steps to improve accessibility. However, we notice that the notifications often lack sufficient specificity when submitted. As a result, we are unable to properly assess what the exact accessibility issues are and where they are located. To clarify the EAA notifications, this EAA update provides further instructions on how to answer certain questions in the EAA notification form.

We are conducting a compliance review on the accessibility of the sector

To assess the state of the sector, we will be conducting an accessibility compliance review in the coming months. We will assess the extent to which institutions' websites comply with the WCAG criteria, paying specific attention to level A criteria. We will focus on sectors and services most frequently used by consumers. If necessary, institutions may be addressed about identified shortcomings.



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AFM

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