The Dutch Authority for the Financial Markets has published its second update on the European Accessibility Act (EAA), setting out expectations for financial firms to take a proactive approach to accessibility as a permanent component of acting in customers’ best interests. It calls on firms to identify whether their services fall within the EAA’s scope, to address remaining implementation gaps, and to embed accessibility in governance and day-to-day operations. The update highlights the EAA’s broad reach, including providers of consumer banking services and financial e-commerce services, with examples such as crypto platforms for electronic money and online insurance providers. Based on exploratory work, the AFM notes that firms making faster progress tend to articulate a clear accessibility vision, elevate accessibility to a strategic KPI, treat implementation as a structured change programme, involve outsourcing partners early, and use gap analyses, alongside appropriate expertise and tools for continuous monitoring. It also flags that while many firms have advanced on compliance and strategy, integration into decision-making processes lags, and suggests distinguishing customer journeys for customers with and without disabilities to better monitor whether services are effectively accessible. The AFM reiterates that, from the EAA’s entry into force, financial firms must notify when they do not meet EAA accessibility requirements or when they rely on an exemption ground such as disproportionate burden. A further EAA update is expected in early 2026.

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