The EU Accessibility Act
The European Accessibility Act (EAA) is a Directive established by the European Parliament and Council, aimed at unifying accessibility standards for products and services throughout the EU. By establishing guidelines based on the principles of perceivability, operability, understandability, and robustness, the Act addresses the growing demand for accessible solutions, driven by an increasing population of individuals with disabilities and an aging society. The Accessibility Act sets out requirements to ensure that a wide range of products and services in the business-to-consumer (B2C) sector are accessible to individuals with disabilities. It covers areas such as computers, operating systems, smartphones, banking services, and e-commerce platforms, requiring them to support features that accommodate various impairments. Physical interfaces like ATMs, ticketing machines, and check-in kiosks must also be designed to be usable by people with disabilities. Additionally, the Act includes services related to audio-visual media, telephony, digital television, e-books, and passenger transport. Consequently, a variety of service providers fall under the scope of the European Accessibility Act and therefore must comply with its requirements, which include:
- Accessibility across services: Ensuring that all user-facing communication, digital platforms like mobile banking apps, customer support tools, payment services, and various processes such as identification methods and electronic signatures are perceivable, operable, understandable, and robust.
- Simplified language use: Maintaining a language complexity below the B2 level for all customer-facing services and products to ensure clarity and accessibility.
- Ongoing compliance monitoring: Developing and implementing processes that continuously monitor compliance with accessibility standards to maintain adherence.
- Documentation and reporting: Companies are obligated to document their compliance initiatives and be prepared to provide evidence to national authorities proving that they meet the Act’s requirements.
For a more comprehensive overview on the services covered by the EAA, please refer to the first part of our blog post series on the Accessibility Act here.
Impact on product and contractual documentation
The European Accessibility Act extends beyond digital services and products, it also has a significant impact on product documentation and consumer contracts. Ensuring that all client-facing documents, such as product manuals or product specifications, are compliant with accessibility requirements, is crucial. While companies often focus on ensuring that their digital presence is compliant, contracts and other documents can often be overlooked. Products and services that otherwise adhere to the regulatory standards remain unusable for customers who rely on assistive technologies, if the corresponding documents are not also made accessible. This particularly means offering detailed explanations on product functionality and use, as well as accessibility features and compatibility with assistive devices.
This means:
- Information must be accessible through multiple sensory channels, such as supplementing written guides with video tutorials that include auditory explanations.
- Information must be presented in an understandable and perceivable manner. This requires the use of plain language and intuitive organisation to ensure accessibility for all users, regardless of their cognitive capacity or reading ability, as well as ensuring compatibility with assistive tools such as screen readers.
- Information must be provided in text formatting that can be used to generate alternative assistive formats, such as ensuring sufficient color contrasts and using appropriately sized fonts.
- Information must be delivered in an appropriate and consistent manner, ensuring it is:
- Perceivable by including visual or auditory alternatives for all content to make it accessible for users with sensory impairments;
- Operable by making user-interfaces easily navigable for users with motor impairments;
- Understandable by using simple language and providing clear instructions to ensure users of all literacy levels can comprehend and interact with content effectively;
- Robust by maintaining compatibility with various assistive technologies and devices.
- Information, in case of non-text content such as images, must be made accessible through text alternatives. These alternatives, often referred to as “alt-text” or “image descriptions”, should clearly convey the visual content by providing more than a generic description. This includes detailing the image's function, as well as specific attributes like size and color.
Do Swiss companies also need to follow the European Accessibility Act?
This Directive applies to all organisations placing their products or services in the EU market, excluding microenterprises with fewer than 10 employees and an annual turnover or annual balance sheet below EUR 2 million. The EAA does not differentiate between companies headquartered inside or outside the EU, as long as they offer goods and services to EU customers and conduct business within EU member states. Even if a provider does not directly serve EU clients, it may still face indirect effects, as business partners might require compliance with accessibility standards to meet contractual obligations.
Essentially this means significant changes for consumer banking providers in the following key areas:
- Reviewing and adapting their online presence. Both websites and mobile services need to be adjusted to fulfill the Acts’s requirements.
- Implementing comprehensive accessibility measures for product and contract documentation. All customer-facing documents must be compatible with assistive technologies.
- Simplifying information to not surpass a B2 language proficiency level. Banks will need to reassess and modify any information provided as part of their banking services.
Addressing these standards ensures ongoing compliance and improves usability for everyone.
How can we help you?
At PwC, we offer support across various areas, including:
- Conducting comprehensive evaluations of your products, services and digital interfaces to ensure they meet accessibility standards.
- Creating detailed measures for the adaptation of processes, products, and services to align with the requirements of the EAA.
- Closely collaborating with the client to ensure successful implementation of the identified accessibility measures.
For more information, please reach out to our experts.
