AFM Steps Up Pressure on Financial Firms to Strengthen Digital Accessibility Compliance

Key Takeaways

• Regulatory Expectations Raised: The AFM is pushing financial institutions to formally identify accessibility risks and embed compliance into internal processes and governance.
• WCAG Standards Are Central: Firms must meet Level A and Level AA requirements under the European Accessibility Act, using WCAG as the benchmark for digital accessibility.
• Notification Quality Under Scrutiny: Many non-compliance notifications lack sufficient detail, prompting the AFM to issue clearer guidance on reporting expectations.
• Compliance Review Incoming: The AFM will conduct a sector-wide review of digital accessibility, focusing on high-use services and adherence to WCAG Level A criteria.

Deep Dive

In its latest update tied to the European Accessibility Act, the Netherland's Autoriteit Financiële Marktenthe laid out guidance for firms navigating accessibility requirements, while making clear that oversight will intensify in the months ahead. The aim is to ensure that people with disabilities can access and manage financial services independently in an increasingly digital environment.

The AFM’s message lands at a moment when many institutions are still refining how accessibility fits into their broader compliance and operational frameworks. The regulator is now urging firms to move beyond surface-level fixes and take a more structured approach, one that starts with identifying accessibility risks across their digital services and embedding compliance into internal processes.

Central to that effort are the Web Content Accessibility Guidelines, the internationally recognized benchmark for accessibility across websites, apps, and digital documents. Under the European Accessibility Act, firms are expected to meet both Level A and Level AA standards. For the AFM, compliance is not simply about meeting a checklist. It is about ensuring that accessibility is built into how services are designed, maintained, and monitored over time.

The regulator’s update also highlights a quieter but telling issue: how firms communicate their shortcomings. Financial institutions are required to notify the AFM when they do not comply with EAA requirements. While many have done so, the regulator notes that these notifications often fall short on detail, making it difficult to assess the nature and scope of accessibility issues.

To close that gap, the AFM has provided additional guidance on how firms should complete their notifications, aiming to bring more clarity and consistency to the process. The underlying signal is that transparency is now part of the compliance expectation, not an afterthought.

That push for greater accountability will soon be backed by direct supervisory action. The AFM confirmed it will carry out a compliance review of the sector’s digital accessibility in the coming months, focusing on how well institutions’ websites align with WCAG criteria. Particular attention will be paid to Level A requirements and to services most commonly used by consumers.

Where shortcomings are identified, firms can expect to hear from the regulator. Accessibility is no longer being framed as a technical enhancement or a reputational consideration. It is emerging as a core component of regulatory compliance, tied directly to consumer protection and the integrity of digital financial services.

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