PDF Accessibility for Banks & Financial Institutions

European Accessibility Act Requirements for Banking

The European Accessibility Act (EAA) represents a fundamental shift in how financial institutions must approach digital document accessibility. Coming into force on June 28, 2025, the EAA mandates that all banking services—including digital documents like account statements, loan agreements, and investment prospectuses—must be accessible to people with disabilities.

Unlike previous accessibility guidelines that were often advisory, the EAA carries legal weight with enforcement mechanisms and potential penalties up to €3 million for non-compliance. For banks operating across multiple EU member states, this creates both a compliance obligation and an operational challenge: ensuring consistency across diverse document types and languages.

The regulation specifically targets "products and services" in the banking sector, which the European Commission has interpreted to include all customer-facing documents. This means your quarterly statements, mobile app PDFs, and even email attachments fall under the scope of compliance requirements.

WCAG 2.2 AA Requirements for Banking PDFs

WCAG 2.2 AA forms the technical foundation for EAA compliance in banking documents. The 55 success criteria are organized around four principles: Perceivable, Operable, Understandable, and Robust (POUR). For PDF documents specifically, several criteria are particularly relevant to banking.

Perceivable requirements ensure that all information can be accessed by customers using assistive technologies. This includes proper text alternatives for images in annual reports, correct reading order in multi-column statements, and sufficient color contrast in charts and graphs.

Operable requirements mean that interactive elements like form fields in loan applications must be keyboard accessible. Customers should be able to navigate and complete forms without a mouse.

Understandable requirements address document structure and labeling. Clear headings in complex documents, properly labeled form fields, and consistent navigation help all customers—but especially those using screen readers.

Robust requirements ensure compatibility with assistive technologies through proper PDF tagging and structure. This is where PDF/UA certification becomes critical.

Common Accessibility Failures in Banking Documents

After auditing hundreds of banking documents, we've identified the most frequent accessibility failures that put financial institutions at compliance risk.

Untagged or incorrectly tagged PDFs are the most common issue. Many banking systems export documents without proper PDF tags, making them completely inaccessible to screen readers. Even when tags exist, they're often incorrect—tables marked as paragraphs, or headings applied inconsistently.

Missing alternative text on images, charts, and graphs is prevalent in annual reports and investment materials. A chart showing quarterly performance is meaningless without a text description of the data it represents.

Improper reading order affects multi-column layouts common in statements. Screen readers may jump between columns unexpectedly, making documents confusing or impossible to follow.

Inaccessible forms are a critical failure point. Loan applications and account opening forms often have unlabeled fields, missing instructions, or form fields that can't be accessed via keyboard.

Color-only information in charts and alerts excludes customers with color blindness. When red means "alert" and green means "normal," approximately 8% of male customers may miss important information.

Banking Document Accessibility Implementation Roadmap

Achieving EAA compliance requires a systematic approach that balances immediate compliance needs with long-term process improvements. Based on our experience with financial institutions, we recommend a phased implementation.

Phase 1: Audit and Assessment (Weeks 1-4) Begin with a comprehensive audit of your document portfolio. Identify all customer-facing document types, their current accessibility status, and remediation complexity. This creates a clear picture of your compliance gap and prioritization framework.

Phase 2: High-Priority Remediation (Weeks 5-12) Focus on documents with the highest regulatory risk and customer impact: account statements, loan agreements, terms and conditions, and privacy policies. These documents should meet full PDF/UA and WCAG 2.2 AA compliance.

Phase 3: Source System Updates (Weeks 8-16) Work with IT to update document generation systems to produce accessible output natively. This is critical for sustainable compliance—manual remediation of every document isn't scalable.

Phase 4: Staff Training and Process Integration (Ongoing) Train staff who create or modify documents on accessibility requirements. Integrate accessibility checks into document approval workflows to prevent new compliance issues.

Phase 5: Monitoring and Maintenance (Ongoing) Establish regular accessibility audits and monitoring to ensure continued compliance as regulations evolve and new document types are introduced.