What the EAA actually requires for banking, in plain terms
"Consumer banking services" is one of the six service categories set out in Schedule 1 of S.I. No. 636/2023. The Central Bank of Ireland's own guidance describes in-scope services as including mortgage agreements, consumer loan agreements, and payment services provided to individual consumers — delivered through websites, mobile banking apps, and the identification, security and electronic-signature steps that sit around them.
The functional requirements follow the same pattern as elsewhere in the EAA: information has to be available through more than one sensory channel, presented so it can be perceived and understood, and the digital channel — online banking, the mobile app, onboarding, statements, payments — has to be usable by people with disabilities, including people using assistive technology. Physical banking products such as ATMs sit in the EAA's separate "self-service terminal" product category rather than the banking-services category, so a bank's obligations here can span both product and service rules depending on what it operates.
WCAG is the practical technical framework most evaluators use to test the digital channel against these functional requirements. As with every sector, a WCAG evaluation on its own is not a legal opinion that a bank or fintech meets every EAA obligation — the Central Bank also expects accessible-format disclosures and documented support processes that sit outside a pure code-and-content review.
Who's exempt
- Microenterprises providing services — fewer than 10 employees and annual turnover or balance-sheet total not exceeding €2 million — are exempt from the EAA's service obligations. Check both the service category and the current figures rather than inferring the answer from a “fintech”, “start-up” or “small business” label.
- Products aren't covered by the services exemption. If a firm also supplies in-scope hardware — payment terminals or self-service machines, for example — the microenterprise services exemption does not extend to those product obligations.
- Fundamental alteration or disproportionate burden can limit specific requirements only where the regulations' conditions are met and documented — not as a general opt-out.
Which regulator enforces it, and what evidence they expect
Unlike e-commerce or e-books, consumer banking services are not a CCPC matter. The Irish government's EAA overview names the Central Bank of Ireland as the authority responsible for banking and financial services. The Central Bank's own EAA page sets out that it supervises credit institutions, payment institutions, electronic money institutions, credit unions, MiFID investment firms and retail intermediaries, and describes its role as supervising compliance, enforcing the standards, and informing consumers about their rights under the regulations.
The evidence the Central Bank expects a regulated firm to be able to show goes beyond a technical accessibility report: published information about service accessibility in accessible formats (written and oral), clear documentation of accessibility features in terms and conditions, evidence that websites, apps and mobile services meet the applicable standards, documentation of how products work with assistive devices, and records of accessible customer-support options. A firm relying on the microenterprise exemption should still keep headcount and turnover or balance-sheet evidence on file, per the same CCPC-published exemption test used across all EAA sectors.
A practical self-check before commissioning an evaluation
- Confirm that the service is an in-scope consumer banking service and identify the relevant authorisation category — for example, credit institution, payment institution, e-money institution, credit union, certain MiFID investment services or mortgage-credit intermediation. Do not assume every financial app is covered by this category.
- Map every consumer-facing digital touchpoint: onboarding and identity verification, mobile app login and navigation, statements and transaction history, payment initiation, and the dispute or complaints process.
- Check what accessible-format disclosures you already publish — the Central Bank's expectations go beyond the website itself, into how accessibility information and support options are communicated.
- Confirm the microenterprise test with real numbers if you think it might apply, rather than assuming a small team automatically qualifies.
- Decide the WCAG version, conformance level and representative journeys you want an evaluation to cover before requesting quotes.
Our accessibility evaluation service scopes exactly these questions with the client before work begins, and records limitations rather than presenting a sampled review as a certification of compliance.
Primary sources and evaluation guidance
- S.I. No. 636/2023 — European Union (Accessibility Requirements of Products and Services) Regulations 2023
- Government of Ireland: European Accessibility Act overview and regulators
- Central Bank of Ireland: European Accessibility Act
- CCPC: European Accessibility Act guidelines for microenterprises
- W3C: Web Content Accessibility Guidelines 2.2
- W3C: Website Accessibility Conformance Evaluation Methodology
Read next
- European Accessibility Act in Ireland: full website guide 2026
- Does the EAA apply to my Irish e-commerce site?
- Does the EAA apply to my Irish passenger transport business?
- Accessibility audit service details
Need this checked properly?
Use the brief call to identify your consumer-facing digital journeys, your Central Bank authorisation category, and the WCAG version and evidence an evaluation should cover. Implementation, once findings are in hand, is a separate step you can hand to your own developer or agency of choice.