Notes · Point of view · 8 min read
Accessibility is law now
On 28 June 2025 the European Accessibility Act stopped being a deadline and became the floor. Banking, credit, payments: the exact things I design are named in its scope, and this is the first full year with auditors on the clock. Most teams are still treating accessibility as a virtue. It is now a legal requirement with a fine attached, and it was always the better design.
What the Accessibility Act actually says
The European Accessibility Act is an EU directive, transposed into the national law of every member state, and it applies to the consumer-facing digital economy: e-commerce, transport, e-books, telecoms, and, in explicit words, banking services, consumer credit, payments and e-money. If you ship consumer fintech anywhere in the EU, the sensible working assumption is that what you ship today is in scope today.
The technical benchmark behind it is EN 301 549, which folds in WCAG 2.1 AA, the same criteria accessibility people have been pointing at for years. Enforcement is national, and it started fast: France issued formal legal notices to major retailers within weeks of the deadline, and the penalty ceilings are real money, around €900,000 in Sweden, €75,000 per violation in France with daily penalties on top. Authorities can also order a non-compliant service off the market, which for a bank is a considerably scarier sentence than any fine. Level Access keeps a solid plain-language summary of who is covered and what enforcement looks like.
I design credit and payment products for EU markets from Tallinn. This law is aimed at exactly the screens on my desk, which is why I have opinions about it. The main one: the fine is the least interesting reason to do this work.
Nearly everything fails, and not exotically
Every year WebAIM runs an automated audit of the top million home pages. The 2026 edition found detectable WCAG failures on 95.9% of them. Not obscure ones: low-contrast text sits on 83.9% of home pages, at an average of 34 separate instances per page. Around half are missing form labels. Nearly a third have buttons with no name. The web is failing the audit with the same five mistakes, a million times over.
Look at that list with fintech eyes and it stops being abstract. Low-contrast text is your gray fee line and your “terms apply”. The unlabeled input is your KYC form with placeholder-only fields, where the hint vanishes the moment someone types, which is exactly when a stressed person re-checks what the field wanted. The unnamed button is your icon-only navigation. I argued for a contrast budget in the eye-tracking note purely on conversion grounds; it turns out the same gray text is also a compliance finding with a price tag.
And the people this excludes are not a rounding error. Disability is permanent, temporary and situational: a broken wrist, a phone in bright sun, a screen reader, a tremor, being seventy and holding your savings in an app designed by someone twenty-six. In fintech there is a special multiplier, because money stress makes everyone temporarily worse at reading. The customer disputing a failed payment at 2am is not operating at full acuity, and the interface that survives that moment is, not coincidentally, the accessible one.
The audit might cost you a fine. The gray text costs you customers every day.
Six failures, all of them already on your roadmap
WebAIM’s failure list maps onto a fintech product with uncomfortable precision. The low-contrast text is the fee disclosure, which is the one line regulators and customers both need to find. The missing alt text is your trust badges and your charts, silent to a screen reader. The missing labels live in the KYC flow, the highest-stakes form in the product, the one I keep insisting is your real onboarding. The empty buttons are the icon-only toolbar. If a control has no accessible name, it does not exist for a screen reader, for voice control, or for the AI agents that have started operating interfaces on people’s behalf; I wrote about those in your next user isn’t human.
Then there is the keyboard, the oldest assistive technology in the book. A styled div with a click handler looks identical to a button and is invisible to the Tab key. Modals that trap focus, or lose it into the void behind the dialog, turn a payment flow into a locked room. And error messages that appear as a red flicker of text, announced to nobody: on a bad day, the customer who most needs to know what happened is the one who never hears it. The bad day, as usual, deserves to be designed first.
None of these are hard problems individually. That is what makes the 95.9% embarrassing: it is not a wall of impossible engineering, it is a million small decisions nobody was asked to make on purpose.
Monzo: big type, ink-dark contrast, buttons that say what they do. Accessibility as confidence
Wise: a visible label on every field, no placeholder-only inputs. The KYC form done properly
Apple Health: hierarchy you can read from arm’s length. Contrast is a kindness before it is a criterion
Cheap early, expensive late
Accessibility retrofitted at audit time is the most expensive version of this work. Designed in from the start, it is nearly free, and most of it is habits rather than heroics:
- Check contrast where colours are born. If the design tokens pass, the screens mostly pass. A contrast budget is a token decision, not a QA ticket.
- Design focus states like you design hover states. The focus ring is brand surface. If it looks like an afterthought, keyboard users are told they are one.
- Give every control a name. Written in the spec, next to the label copy. If you cannot phrase what a screen reader should say aloud, the control is not designed yet.
- Draw the tab order on the flow. It costs minutes per screen and it catches the div-buttons, the focus traps and the modals that eat the keyboard.
- Run the two-tool ritual. Once per flow: keyboard only, then a screen reader. You will find real bugs that sighted mouse testing never surfaces, some of them plain conversion bugs.
When I rebuilt the Lightyear help centre, plain language, visible structure and named actions were the whole strategy, and the same choices that made it readable under stress are the ones an auditor would now tick. That is the general shape of this law: it mostly demands the version of your product that was already better.
And there is a twist that makes 2026 the strangest year to skip this work: the same semantics that serve a screen reader are what AI agents parse when they operate your product. Nielsen Norman Group spent the spring making exactly this point, that interfaces built accessibly are already legible to machine users. The work is suddenly paid twice. The care was always the better reason; now the invoice arrives either way.
Worth reading alongside this note:
- The European Accessibility Act, the directive itself, from the source
- Level Access: EAA compliance overview, scope, dates and penalties in plain language
- The WebAIM Million, the annual audit behind the 95.9%
- GOV.UK: dos and don’ts on designing for accessibility, still the best one-page posters on the subject
- GOV.UK service manual: making your service accessible, the calm, practical introduction