Eximee Team
Implementing the WCAG standard is becoming a necessity for banks. However, it's important to remember that it's not just a legal requirement that has to be met. Improving the accessibility of websites and applications can bring many financial and reputational benefits to institutions. So why is it worth taking care of, and where should you start?
The Web Content Accessibility Guidelines (WCAG) are a set of guidelines created by the World Wide Web Consortium (W3C). The aim of these guidelines is to ensure that online content is fully accessible to users with various disabilities, including visual, hearing and motor impairments.
According to the European Accessibility Act, these guidelines must be implemented in the financial sector by 28 June 2025.
This article explores the topic of WCAG in the context of modern financial institutions. You can find a detailed explanation of what WCAG is, its history, its criteria, and how a WCAG audit works here.
Legal Obligations for Banks Regarding WCAG (post-2025)
From a bank's perspective, implementing WCAG standards is a way to comply with the EAA directive and avoid sanctions or legal risks. However, for many institutions, these may be the main motivations.
In Poland, the right to file a complaint regarding a lack of accessibility was introduced on 6 September 2021. Initially, this only applied to public entities. However, according to the European Accessibility Act, from 28 June 2025, these guidelines will also apply to private entities.
What does this procedure look like in practice?
Any Polish citizen who encounters an accessibility barrier can submit a request for accessibility to be ensured. In such cases, the entity is required to ensure accessibility within 14 days. An exception exists if the entity informs the applicant that more time is needed to implement the changes. However, this period cannot exceed two months.
If the entity fails to comply with the request, a person with specific accessibility needs may file a complaint with the PFRON (Prezes Państwowego Funduszu Rehabilitacji Osób Niepełnosprawnych), which translates as 'President of the State Fund for the Rehabilitation of Disabled Persons'.
According to current Polish law, banks that fail to comply with the EAA's guidelines may face financial penalties of up to 10% of their annual turnover.
However, it's important to consider this issue from a broader perspective and take into account the welfare of both current and future customers. Making digital services accessible will increase trust in the bank as an institution that prioritises its clients' well-being. It will also enable people with disabilities to use the bank’s services and may help attract new clients.
Accessibility of banking services – user perception
It is worth remembering that, in 2023, 28.8% of people with disabilities in the EU were at risk of poverty or social exclusion, compared to 18.8% of people without disabilities. These statistics clearly indicate the ongoing need to enhance service accessibility.
Similar conclusions can be drawn from a Deloitte report in the context of the financial sector, where only 8% of respondents believed that banking services (such as bank branches and ATMs) were adequately accessible. Furthermore, nearly half (45%) of respondents emphasised that the quality of banking services could be improved by making digital channels more accessible.
The data highlights a much broader issue: the need to adapt physical infrastructure. While this is certainly an issue that cannot be ignored, it can be addressed by making digital services more accessible and designing them so that individuals with disabilities can use them independently.
A WCAG audit consists of 50 criteria, divided into three levels of accessibility: A (basic), AA (extended) and AAA (most advanced). These criteria determine precisely to what extent a given institution meets the fundamental WCAG requirements of perceptibility, operability, understandability and robustness.
Here’s what these criteria involve and how they relate to the financial sector:
According to this criterion, a website or application must ensure that all elements are accessible using one of the senses (e.g., sight, hearing). Adhering to this principle requires institutions to provide text alternatives for graphical content, which can be read by assistive tools.
It is also necessary to allow users to independently zoom content on the page up to 500% while maintaining readability and proper page functionality.
Similarly, for users with hearing impairments, they must be able to access audio content through captions. In the case of audio and video materials, users should have access to features like audio descriptions or sign language interpretation.
In the banking sector, it is especially important to ensure that users can independently access important documents without needing third-party assistance.
This criterion covers the various ways in which users can interact with the available content on a website or mobile application. It is particularly beneficial for individuals with limited motor skills, and includes the ability to navigate using only a keyboard, for example.
Another way this criterion can be implemented is by ensuring users are given sufficient time to respond to notifications or authorise transactions.
The aim of fulfilling this principle is primarily to make the website easy to understand for everyone. Its core focus is on using simple language and providing instructions and messages that clearly address user questions and clarify doubts.
In the context of website or application accessibility, understandability should also be interpreted as simplicity and intuitive navigation. In the banking sector, this can be achieved by using clear, understandable messages and simple instructions for filling out forms.
Banks and financial institutions are required to provide clients with specific needs with a contract in an accessible format, such as an audio recording, a Polish Sign Language video recording, a Braille printout or large-print text (Article 46).
According to this criterion, websites and mobile applications must be compatible with assistive technologies, such as screen readers. They should also function correctly across various devices, browsers, and operating systems (iOS, Android, Windows).
It is particularly important to ensure the compatibility of the website with assistive tools available on different systems, as these tools often behave differently in the same situation.
For screen readers, one particularly important aspect is the need to properly define the language of the entered content. This ensures that the tool does not begin reading content in Polish using a voice designed for English text.
You can find more information on the differences between various screen readers and how to test accessibility with them in the following article.
Implementing the Web Content Accessibility Guidelines (WCAG) in banks is a complex process that requires the involvement of many individuals, from banking system designers and testers to management teams within the banks.
It is not something that can be done 'on the side' – ensuring digital accessibility requires banks to adopt a user-centred design philosophy from the outset that focuses on users with specific needs.
To carry out this process properly, a team of specialists is required who have expertise in UX design, web and mobile application development, WCAG guidelines, and accessibility.
Only such specialists will be able to take a comprehensive approach to all the challenges related to designing accessible services, identify key issues and formulate guidelines to resolve them.
One popular solution is to hire external companies to adapt existing systems to WCAG guidelines. However, this approach raises issues regarding decision-making – responsibility for the most crucial aspects of this process should rest with decision-makers within the bank, not external companies. Ultimately, this means that the person responsible for making these decisions must be thoroughly trained in all related aspects.
Some institutions still do not have a properly designed or carried out process for implementing WCAG.
A comprehensive approach is lacking: the process has not been planned from start to finish, an audit has not been conducted, and its results have not been translated into specific guidelines for technology partners or external service providers.
The most important thing is to understand that compliance with WCAG should not be treated as a 'task to outsource' – for example, by entrusting it entirely to an external contractor.
The institution, not the vendor, bears ultimate responsibility for the accessibility of its systems, and it is the institution that will be audited.
Therefore, it is crucial to design the entire implementation process from start to finish, define its stages, and establish measurable criteria to determine when they have been successfully achieved.
In particular, banks should pay attention to:
Another common issue when implementing WCAG in financial institutions is the absence of a shared vision that encompasses all systems.
In practice, this often manifests as various applications from different vendors receiving a general instruction: 'Adapt the system to WCAG.' While this may seem sensible, it doesn't lead to a cohesive result.
Why?
Because digital accessibility is not just about meeting minimum requirements – it must form part of a broader design approach.
When vendors work independently without coordination, inconsistencies can arise, such as different colours, disparate navigation solutions and a lack of uniform terminology. Meanwhile, users should feel as though they are navigating a single, logically designed environment.
Rather than adapting each system separately, a common accessibility architecture should be designed from the outset with a unified visual and technological logic.
This requires coordination and oversight to ensure consistency across the entire environment, from the UI to contrast to interaction logic.
All the issues described earlier can be solved, but not immediately.
Implementing digital accessibility requires time, strategic planning and the involvement of the right people within the organisation.
The stages of implementing digital accessibility in a bank.
It is important to adopt a 'WCAG-first' mindset, designing systems that are accessible from the outset and taking the real needs of users into account. WCAG should not be treated solely as a checklist from the W3C document. The goal is to create applications and products that are truly accessible and intuitive to use, regardless of the user's limitations.
If systems were not built this way from the outset, it is important to introduce consistent standards when developing subsequent solutions.
When adapting existing applications, it is crucial to ensure consistency in approach, both visually and functionally.
The IT team responsible for creating and maintaining banking systems must receive proper training in WCAG principles, so that they can apply them at every stage of the software development process.
Banks should not assume that WCAG guidelines will be implemented by an external party. Internal competencies are necessary, both within development teams and in areas such as UX, testing and product management.
The aim of employee education is to embed accessibility into the organisational culture. Without proper preparation, teams may not understand how to implement WCAG requirements practically, which often leads to costly mistakes and delays.
What training should be conducted?
The first and most important element in the implementation of digital accessibility is thorough internal documentation. This knowledge base directly impacts the quality of work within teams and the efficient functioning of the entire organisation.
This documentation should include principles that align with WCAG standards and general accessibility requirements for digital products, as well as detailed guidelines for design, development and product teams. This documentation acts as a reference point for all employees, from developers and designers to managers, helping them to understand how to create new functionalities in line with accessibility principles, and how to implement changes to existing systems properly.
It may include guidelines for designing accessible forms, principles for navigation and content structure, and standards for writing understandable error and message texts. It should also provide instructions for testing accessibility, for example using tools such as Axe, NVDA, or Lighthouse.
Adapting digital systems to WCAG guidelines is a complex and multifaceted process that may seem inaccessible and difficult for many organisations to implement independently.
Fortunately, it is not necessary to start from scratch: banks wanting to ensure their solutions meet accessibility requirements can benefit from the support of experienced technology partners.
These partners are familiar with WCAG standards and the specifics of their implementation. They also understand the common challenges and mistakes made by financial institutions when trying to implement them. Armed with this knowledge, they can help banks avoid these pitfalls and implement accessibility effectively.
By working with a trusted provider, banks can focus on their core competencies while ensuring their digital products and services comply with accessibility requirements and are ready for upcoming regulations.
Implementing WCAG guidelines in a bank is a complex process that requires appropriate procedures, resources, and the involvement of various teams. It is not only about technical preparation but also involves conducting internal training and creating comprehensive documentation that will serve as real support in daily operations.
It is also beneficial to seek support from a trusted provider with the necessary knowledge and experience to guide the organization through the entire process efficiently.
Banks that successfully implement accessibility standards not only meet legal requirements but also build a competitive advantage – offering services tailored to the needs of all customers, including those with disabilities.
Learn how to benefit from professional support in digital accessibility. Contact our specialist!
