On 24 April 2025, the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten, the AFM) published a news update concerning the European Accessibility Act (Directive (EU) 2019/882, the EAA), which will become applicable in the Netherlands as of 28 June 2025. In this news item, the AFM urges financial institutions to take the necessary steps, if they have not already done so, to ensure timely compliance with the EAA and provides practical examples to help institutions meet the directive’s requirements.

Background on the EAA

The EAA introduces harmonised accessibility requirements for a wide range of products and services across the EU. For the financial sector, this includes, among other things, the provision of credit agreements, investment services and activities (including ancillary services), payment services, e-money, and services related to payment accounts. In addition, the financial sector falls within the scope of the EAA where it concerns financial ‘e-commerce services’,  essentially, the offering of financial services via the internet at the consumer’s request, with the aim of concluding an agreement. The goal of the EAA is to remove barriers that prevent people with disabilities from fully participating in the digital economy. It also offers businesses a chance to align with growing expectations around corporate responsibility and inclusive service delivery.

Four principles of accessibility

Under the EAA, all digital services must be developed and maintained in accordance with four principles of accessibility:

  • Perceivable: information must be presented in ways that can be perceived by all users, including those using assistive technologies.
  • Operable: interfaces must be functional for users with different interaction methods (e.g., keyboard navigation).
  • Understandable: content must be clear, consistent, and easy to comprehend.
  • Robust: digital content must remain compatible with various current and future technologies, including assistive devices.

Financial institutions are required not only to make their digital services accessible, but also to establish internal processes to ensure accessibility is maintained over time. This means accessibility should become an integral part of service design, implementation, and monitoring.

Practical examples

An example of a practical step towards compliance is to conduct accessibility surveys of digital channels to assess user experiences and identify areas for improvement. Common improvement measures include:

  • enhancing site navigation for better usability;
  • adjusting colour schemes and contrast to support visual accessibility; and
  • adding descriptive text (alt text) to images for screen readers.

These are not merely recommendations. The AFM expects institutions to take proactive, measurable steps toward compliance. Further practical guidance on how to meet these expectations is provided in the AFM’s downloadable publication, the EAA Update 1 (available here).

Call to action

The AFM notes that it has already observed strong examples of digital accessibility efforts at several financial institutions, demonstrating that meaningful progress is achievable. The AFM also calls on those financial institutions who still have ground to cover.

What the AFM expects now

In light of the upcoming implementation deadline, the AFM calls on financial institutions to, among other things:

  • conduct a gap analysis to identify the measures needed to achieve compliance with the EAA;
  • develop or update internal policies that address digital accessibility;
  • build internal expertise on digital accessibility and embed this knowledge throughout the organisation; and
  • establish monitoring procedures to ensure continued compliance over time.

Further guidance from the AFM is expected closer to the application date, but immediate action is strongly recommended. For more detailed information, firms can access the AFM’s EAA update 1 here.