From a financial services perspective, the Act includes within its scope:

• credit agreements covered by the Consumer Credit Directive;
• credit agreements covered by the Mortgage Credit Directive;
• the following investment services (and ancillary services) covered by MiFID;
  • reception and transmission of orders;
  • execution of orders on behalf of clients;
  • portfolio management;
  • investment advice;
  • safekeeping and administration for the account of clients;
  • granting credits or loans to an investor to allow them to carry out a transaction, where the firm is involved in that transaction;
  • foreign exchange services where these are connected to the provision of investment services; and
  • investment research and financial analysis;
• payment services covered by the Payment Services Directive;
• payment account services covered by the Payment Accounts Directive; and
• electronic money services covered by the E-Money Directive.

Firms that provide services within the scope of the Act must ensure that such services comply with certain accessibility requirements. The requirements most relevant to financial services include the following.

1. Accessible information and communication: All information provided to users (such as contracts, terms and conditions, marketing materials, and customer support) must be accessible. This includes presenting information in any understandable way and making information available in formats suitable for people with visual, hearing or cognitive impairments.
2. Accessible digital services: Websites, mobile applications and other online platforms must be accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust.
3. Customer support accessibility: Customer support services, including helplines, technical support, relay services and training services must be accessible.
4. Banking tool accessibility: Identification methods, electronic signatures, security and payment services must be perceivable, operable, understandable and robust.
5. Language accessibility: Information must not exceed a complexity level above level B2 of the Council of Europe's Common European Framework of Reference for Languages.
6. Ongoing monitoring: Firms must establish processes to monitor compliance with accessibility requirements.
7. Documentation and reporting: Firms must document their compliance measures and, if requested, provide information to national authorities demonstrating how they meet the Act’s requirements.

In practice, a firm’s potential obligations under the Act will depend on the following.

• Whether the firm deals directly with “consumers” in the EEA.

Firms providing in-scope services to EEA-based retail clients will need to ensure that their offerings or processes meet the Act’s accessibility standards once implemented in the relevant EEA jurisdiction.

• How each EEA Member State transposes and enforces the Act locally.

Since the Act itself does not have direct effect, the specific rules and thresholds for compliance may vary from one EEA jurisdiction to another.

Generally, firms that do not hold local licences to provide regulated financial services in an EEA Member State, or that do not directly engage with retail clients there, will be outside the Act’s scope.

Yes. Even if a firm is not directly subject to the Act, it may still be affected through its relationships with other entities. Should a counterparty that does serve EEA retail clients need to comply with local accessibility requirements, it may request contractual assurances relating to accessibility from all participating firms in the business chain. Consequently, firms entirely outside the Act’s direct scope may nevertheless need to adapt in order to satisfy contractual obligations imposed by partners operating within the EEA.

The Act is set to come into force from 28 June 2025, although its exact application will depend on when each EEA Member State implements the Act at a national level.

In anticipation of 28 June 2025, firms should consider:

• whether they, or any of any of their contractual partners, service EEA-based retail clients;
• whether they provide any services which might fall within the scope of the Act;
• whether they may need to make any changes to their business, including to their policies and procedures, should they need to comply with the requirements of the Act; and
• whether they may need to review their relationships with EEA-based service providers who might require contractual assurances to secure their own compliance with the Act. 

It is currently uncertain how extensively each EEA Member State will adopt and implement the provisions of the Act. In light of this, firms would be well advised to monitor the legislation and guidance in the specific Member States where they operate or maintain customer relationships.