Accessible Banking in the EU

The law firm Travers Smith lists the consumer banking services in scope: credit agreements including consumer loans and mortgages, payment services, services linked to a payment account, electronic money and certain investment services. Websites and apps for these services must be perceivable, operable and understandable, and must work with assistive technology. Information about the service must not go beyond the upper intermediate level of the Council of Europe's language framework (CEFR).

Microenterprises with fewer than ten employees and turnover under 2 million euros are exempt from some requirements. Member states set the penalties, and in serious cases products and services that do not comply can be withdrawn from the market.

The German implementing act names the hardware. Its first section lists payment terminals with their hardware and software, and ATMs, among the self-service terminals that must be accessible when they are placed on the market after June 28, 2025. Banking services for consumers are in scope as services.

Old equipment gets transition periods. Under section 38 of the German act, a bank may keep providing its services with products it lawfully used before June 28, 2025 until June 27, 2030. Self-service terminals already in use may stay until the end of their economic life, but no longer than 15 years after they were first put into operation. The directive itself allows up to 20 years, as Travers Smith notes.

According to Travers Smith, identification methods, electronic signatures, security features and payment services must meet the same requirements. In practice that covers opening an account remotely by video identification or eID, approving a payment in the banking app, and signing a credit agreement electronically.

Payment terminals, banking apps and the rules for them belong to the Payments & Digital Money track at Finance Loop. The payments regulation page covers the other rules that payment providers in Germany follow, and the access to cash page covers the ATM network.

Banking that people with disabilities can use without help: ATMs and payment terminals they can operate, and websites and apps that work with assistive technology and use plain language.

Yes. It covers consumer banking services such as credit agreements, payment services, payment accounts, electronic money and certain investment services, plus ATMs and payment terminals placed on the market after June 28, 2025.

In Germany until the end of their economic life, at most 15 years after first use. The directive allows up to 20 years. Services built on older products may continue until June 27, 2030.

Microenterprises with fewer than ten employees and turnover under 2 million euros are exempt from some of the requirements, according to Travers Smith.