guide
EAA for financial services in Ireland — compliance checklist
Operating a finance & banking business in Ireland after 28 June 2025 means complying with the country's national EAA transposition (European Union (Accessibility Requirements) Regulations 2023) layered on top of EN 301 549 — and addressing finance & banking-specific failure modes including mfa flows incompatible with screen readers and statement and tax-document pdfs not tagged.
EAA in Ireland
Transposition: European Union (Accessibility Requirements) Regulations 2023. Surveillance: CCPC / NDA. Max penalty: €60,000 / 18 months imprisonment.
Finance & Banking accessibility — what is in scope
Banking and insurance are explicitly in EAA scope (Article 2(2)(b) and (e)) with strict 2025 enforcement. In the US, banks have been ADA targets for over a decade; the OCC, Federal Reserve and CFPB have all issued guidance on web accessibility. Multi-factor authentication, statement PDFs, and complex transactional flows are the standard failure points.
Common failures in financial services
• MFA flows incompatible with screen readers
• Statement and tax-document PDFs not tagged
• Charts and graphs without text alternatives
• CAPTCHA blocking screen-reader users
• Inaccessible IVR fallback when web fails
EAA compliance checklist
1. Confirm in-scope status. 2. Map to EN 301 549. 3. Audit and remediate. 4. Publish a localised accessibility statement (Article 13). 5. Maintain technical documentation for market surveillance.
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Does the EAA apply to non-EU financial services selling into Ireland?
Yes. The EAA applies to any product or service placed on the EU market or offered to EU consumers, regardless of vendor headquarters.
What is the maximum penalty in Ireland?
€60,000 / 18 months imprisonment
Is banking in scope of the EAA?
Yes — consumer banking services are explicitly in EAA scope under Article 2(2). All EU-facing consumer banking websites and apps must meet EAA accessibility requirements as of 28 June 2025 (services contracts existing on that date enjoy a transition to 28 June 2030).
How do US banks handle ADA web accessibility?
US banks have been ADA Title III defendants for years. Most large banks now publish accessibility statements, maintain VPATs, and integrate accessibility into product release gates. Federal Reserve and OCC have issued advisory guidance.
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