Yes, if you provide consumer banking services as the Directive defines them. Banks and fintechs are in scope for the services they offer to consumers, and the test is the service, not the company label.

Is consumer banking in scope of the European Accessibility Act?

Yes, because Article 2(2)(d) of Directive (EU) 2019/882 (the European Accessibility Act, EAA) lists “consumer banking services” among the services it covers, for services provided to consumers after 28 June 2025. Germany lists the same group in § 1 Absatz 3 Nummer 3 BFSG as “Bankdienstleistungen für Verbraucher”.

Start with the national act of each country where you offer your service to consumers, not with the language of your site. If you offer to consumers in more than one Member State, check each country’s act. Where your company is based can matter too; for a cross-border case, ask a lawyer which acts bind you.

Which banking services does the Directive list?

Article 3(28) defines consumer banking services as five groups of services provided to consumers. They are credit agreements, certain investment services, payment services, services linked to a payment account, and electronic money.

  • Credit agreements covered by Directive 2008/48/EC or Directive 2014/17/EU (Art. 3(28)(a)).
  • Services defined in points 1, 2, 4 and 5 of Section A and points 1, 2, 4 and 5 of Section B of Annex I to Directive 2014/65/EU (Art. 3(28)(b)).
  • Payment services as defined in point 3 of Article 4 of Directive (EU) 2015/2366 (Art. 3(28)(c)).
  • Services linked to the payment account as defined in point 6 of Article 2 of Directive 2014/92/EU (Art. 3(28)(d)).
  • Electronic money as defined in point 2 of Article 2 of Directive 2009/110/EC (Art. 3(28)(e)).

This guide covers only these five groups. The Directive speaks of services for “consumers”, meaning natural persons acting outside their trade, business, craft or profession (Art. 3(22)), so a service sold only to businesses is a different question. Another service you offer may be listed separately: e-commerce services, for example, are in Art. 2(2)(f).

Does the word “fintech” change the answer?

No, because the Directive defines scope by the service provided to consumers, not by the type of company or its licence. A service provider is anyone who provides a service on the Union market or offers to provide it to consumers in the Union (Article 3(4)).

So a fintech that offers, say, payment services or electronic money to consumers offers services named in Art. 3(28)(c) or (e). Whether your product matches one of those definitions is a legal question that turns on the other directives the definition points to. If you are unsure, ask a lawyer.

Which digital surfaces of a bank or fintech count?

The Directive covers the banking service itself, including where it is provided through websites and mobile device-based services such as mobile applications (recital 39). In practice, start with online banking, the mobile banking app, account opening, payment screens and identification steps.

  • Online banking: the website, from login to statements and settings.
  • Mobile banking app: a mobile device-based service, named in recital 39.
  • Account opening and applications: the forms and steps through which a consumer concludes a listed service, such as a credit agreement or a payment account.
  • Payment services: Annex I, Section IV, point (e)(i) names payment services.
  • Identification and signing steps: the same point names identification methods and electronic signatures. The Directive does not list which methods, so check every step you use.

“The appropriate accessibility requirements should also apply to identification methods, electronic signature and payment services, since they are necessary for concluding consumer banking transactions.”

The quote is recital 40. Annex I, Section IV, point (e)(ii) adds that information must be understandable without exceeding level B2 of the Common European Framework of Reference for Languages. Cash machines are covered as products under Art. 2(1)(b)(ii) and are outside this web-focused guide.

Does the micro-enterprise exemption apply to us?

Microenterprises providing services are exempt from the accessibility requirements for services (Article 4(5)). A microenterprise employs fewer than 10 persons and has an annual turnover of EUR 2 million or less or an annual balance sheet total of EUR 2 million or less (Article 3(23)).

Both parts count: headcount and one of the two money figures. Recital 53 adds that an enterprise must actually meet the requirements of Commission Recommendation 2003/361/EC to benefit, which is aimed at preventing circumvention. Germany repeats the exemption in § 3 Absatz 3 BFSG and the definition in § 2 Nummer 17 BFSG.

It is not the only relief. Article 14 lets an operator rely on fundamental alteration or disproportionate burden; whichever it relies on, it must assess (Art. 14(2)) and document (Art. 14(3)). The exemption covers services only: a microenterprise placing a product such as a payment terminal on the market is not exempt, and gets only the lighter rule of Art. 14(4), which spares it from documenting that assessment.

What should a bank or fintech check first?

Start with a list, not a scan: which of your services appear in Article 3(28) and which of them reach consumers through a website or an app. Then test the pages and flows that list produces.

  1. Write down each consumer service you offer and match it to the five groups.
  2. Check the micro-enterprise test with your headcount and your figures, and note the date.
  3. List every web page, app screen and step: login, account opening, payment, identification, signing.
  4. Run a first automated check on the pages you can reach, then walk the flows by hand with a keyboard and a screen reader.
  5. Prepare the information on how the service meets the requirements (Art. 13(2) and Annex V), and read the key texts for B2 language.

What can automated testing show on a banking site, and what can it not?

Automated testing catches roughly 30 to 40 percent of WCAG success criteria, not 30 to 40 percent of a site’s failures. It can flag a missing form label or low contrast on a page it reaches, and it cannot judge whether a person can finish an identification step.

  • It cannot walk a multi-step flow the way a person with a screen reader or a keyboard does.
  • A scan of public pages does not sign in, so pages behind a login need a person.
  • It cannot judge whether a security prompt or a time limit is operable for the person in front of it.
  • It cannot tell whether your texts stay within level B2, or whether the information you publish is true.
  • A native mobile app is not a web page and needs its own test.

A grade of 100 means nothing automated was found. It does not mean the service is accessible.

How does Inkluso help a bank or fintech?

The free scan tests your homepage against WCAG 2.1 AA with axe-core, with no account and no card. The one-time audit costs EUR 149 and covers up to 100 pages of your website.

  • A dated PDF report with a timestamp, the engine version and a SHA-256 hash.
  • For every finding: the WCAG criterion, the EN 301 549 clause and the paragraph of the national act you select.
  • A keyboard walk in the paid audit. It is heuristic and is not part of the grade.
  • A draft accessibility statement, to review before you publish it.

Inkluso does not work out which law applies to you; the citation follows the jurisdiction you pick. An Inkluso report is not a certification.

What else do banks and fintechs ask?

Four short answers. They repeat the sections above.

Does the European Accessibility Act apply to banks?

Yes, for consumer banking services. Article 2(2)(d) of Directive (EU) 2019/882 lists them, and Article 3(28) defines them as credit agreements, certain investment services, payment services, services linked to a payment account and electronic money.

Does it apply to fintechs?

The Directive defines scope by the service provided to consumers, not by the type of company. A fintech that offers a service named in Article 3(28) to consumers is a service provider under Article 3(4).

Is there an exemption for small providers?

Microenterprises providing services are exempt (Article 4(5)). A microenterprise has fewer than 10 persons and an annual turnover or annual balance sheet total of EUR 2 million or less (Article 3(23)).

Which digital services of a bank are covered?

The banking service, including where it is provided through websites and mobile applications (recital 39). Annex I, Section IV, point (e) names identification methods, electronic signatures, security and payment services.

Which sources does this page rely on?

Every legal statement links to the Directive on EUR-Lex or to the BFSG on gesetze-im-internet.de. All sources were accessed on 2026-10-20.

Want to see where your homepage stands?

The free scan tests the homepage against WCAG 2.1 AA with axe-core and shows the first findings with the matching reference. No signup, no card.

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Related: EAA scope guide · Accessibility statement generator · Other sectors: Online shops · Travel and transport websites · Ticketing websites

Orientation, not legal advice. An Inkluso report is not a certification. Automated testing catches roughly 30 to 40 percent of WCAG success criteria. The rest needs a human.