Read the interviews with Ana Gallego, Director-General for Justice and Consumers at the European Commission, and the reflections from Odile Regnier, Chairwoman of the EACB Consumer Policy working group.
In a world that is becoming ever more digital, guaranteeing access to banking services for all customers - particularly individuals with disabilities - has become a crucial matter. Cooperative banks rooted across all regions in Europe are deeply committed to integrating accessibility into their practices and for their 227 million customers. Their strong customer focus, combined with the core cooperative values - such as trust, solidarity, and proximity to customers - makes accessibility a central priority for them.
Over time, European cooperative banks have undertaken many initiatives to enhance the accessibility of persons with disabilities to their services. Over several years, they have been working to adjust their practices, across their devices (such as ATMs), services, products, websites and applications.
More recently, they have embraced the Directive (EU) 2019/882 on the accessibility requirements for products and services (the ‘European Accessibility Act’). Cross sectoral in scope and applying to many different economic sectors, it represents a landmark piece of legislation with important impact that aims to improve access for persons with disabilities to a variety of products and services.
This newsletter would like to put the spotlight on the EAA as it has become fully applicable on 28 June 2025. We invited the Director-General of the European Commission Directorate-General for Justice and the EACB Chair of the Consumer Policy Working group to reflect on the past and to look forward.
3 Questions to
Anna Gallego
Director-General for Justice and Consumers at the European Commission
3 Questions to
Ana Gallego
Director-General for Justice and Consumers
at the European Commission
Ana Gallego is the Director-General for Justice and Consumers at the European Commission since November 2021. Before joining the European Commission she was Director-General of International Legal Cooperation and Human Rights in the Ministry of Justice in Spain. She has a degree in law from the University of Granada, Spain and studies in Translation and Interpretation from the same university.
The European Accessibility Act became applicable on 28 June 2025, could you briefly remind us what it is intended to do?
On 28 June the so-called “European Accessibility Act” (EAA) entered into application across the EU. Since then, key products and services such as phones, computers, e-books, banking services, and electronic communications must be accessible for persons with disabilities. These key products and services have been carefully selected and are indispensable to ensure the participation of persons with disabilities to all areas of life, including the digital world, economy, work, education, employment, and public administrations online. The Directive strategically includes products that are crucial to access key services of co-operative banks online, such as payment terminals, ATMs, computers and telephones. The EEA also covers consumer banking services and e-commerce, which are particularly relevant to cooperative banks. Readers are invited to get familiar both with the Directive and the relevant national laws transposing it. Businesses providing consumers banking services in the EU market, in addition to the general accessibility requirements related to all services (set forth under Annex I, Section III) of the EAA, need to fulfil the requirements established specifically for these services, laid down in Section IV, lett. (e) of the Annex, namely:
(i) providing identification methods, electronic signatures, security, and payment services that are perceivable, operable, understandable, and robust;
(ii) ensuring that the information is understandable, without exceeding a level of complexity superior to level B2 (upper intermediate) of the Common European Framework of Reference for Languages.
Consumers, persons with disabilities, and their organizations will have the possibility to file complaints in front of national administrative authorities or courts against businesses that do not implement these new rules, with potential penalties at play. Accessibility is no longer an aspirational goal, but a concrete right.
The European Accessibility Act is a file with a very broad scope. We can imagine that this was a complex piece of legislation to formulate and roll out with a lot of different national competent authorities involved. What have been the main challenges in preparing for implementation and how did you overcome them?
Indeed, it took a long time to negotiate the Act. The Commission submitted its proposal in 2015. After intensive negotiations with the European Parliament and the Council, which co-legislate together on EU law, the Act was finally adopted in 2019. EU countries had three more years to transpose its rules by 2022, and another three years to prepare for their application starting from 28 June this year. As the act affects a wide range of products and services, EU countries had to appoint one main contact point to coordinate the process and report to the Commission. We have had lively discussions with Member States to support their transposition. By now, all EU countries communicated that they have transposed the act, and we are assessing whether their transposition is indeed complete, correct, and legally sound. The Commission has also asked the organisations responsible for issuing industry-wide standards (such as CEN, Cenelec, and ETSI) to revise a number of harmonised European standards to support the implementation of the accessibility requirements. We have also created a resource centre called “AccessibleEU” to support businesses and organisations responsible for implementing the new rules.
That was on process. However, the most challenging part was to impress the necessity of accessibility to those not yet familiar with it. Accessibility is a precondition for persons with disabilities to enjoy their human rights and fundamental freedoms on an equal basis with others. To convey this message, that this was a human rights issue, was decisive in the process. Once that was clear, there was support and a joint interest in finding an agreement.
The Commission has established a working group composed of representatives of authorities for market surveillance, and other stakeholders, including disability organisations. Would you be able to provide more details about this working group, including its goals and ongoing initiatives?
Our supportive role does not stop once the act enters into application. The Commission is now in the final stages of setting up the working group required by the Directive. Article 28 of the European Accessibility Act provides details about the composition of the group: it shall consist of representatives of market surveillance authorities, authorities responsible for compliance of services and relevant stakeholders, including representatives of persons with disabilities. The group must facilitate exchanges of information and best practices among the authorities and relevant stakeholders, foster cooperation between them, and provide advice to the Commission. We expect the first meeting to take place in the autumn.
Reflections from
Odile Regnier
Chairwoman of the EACB Consumer Policy working group
& Head of EU Affairs, Confédération Nationale du Crédit Mutuel
Odile Regnier currently serves as the Chairwoman of the EACB Consumer Policy working group. After an extensive period in the Legal Department of the Confédération Nationale du Crédit Mutuel, Odile transitioned to the role of Head of EU Affairs a few years ago. She is the former Chairwoman of the Committee of European Affairs of the French Banking Federation and of the EACB Corporate and Company Law working group. She has been proactively participating in the elaboration of new European regulations, in particular in the area of consumer policy and governance.
Cooperative banks are deeply committed to promoting accessibility across their services. They have shown strong initiative by updating their accessibility practices well before the European Accessibility Act (EAA) came into effect. Indeed, many had already launched their own forward-thinking efforts inspired by Member States’ initiatives that laid the groundwork for today’s evolving standards.
In preparation for EAA compliance, cooperative banks have proactively enhanced their practices by for example:
Developing comprehensive policies and process standards
Launching new products, such as a bank account tailored to improve access for individuals with functional limitations or living with moderate to severe disabilities or non-self-sufficiency, provided they hold the European Disability Card
Delivering dedicated training sessions and webinars for staff
Revamping institutional websites to improve usability
Upgrading Home Banking web and mobile platforms
Enhancing ATM accessibility — including improved screen functionality, color contrast, font sizes, and machine status updates
The rollout of this new regulatory framework marks a positive shift towards more accessible banking services. At the same time, its broad, cross-sector nature presents a learning curve, particularly in the absence of detailed interpretive guidance.
For example, the concept of services provided after 28 June 2025 (as per Article 2, in which we see that the EAA applies to both products and services provided to consumers after 28 June 2025) raises several questions, as it is unclear whether it refers solely to new services that did not exist before this date, subscriptions made after this date for services already provided earlier, or services previously provided but modified as of this date. Smaller and less complex institutions may face added hurdles due to limited in-house resources or specialized departments. With increasing compliance costs across various EU regulations, it is essential for national authorities to remain mindful of these realities, especially in the context of Article 30 of the EAA on Penalties.
Fortunately, tools like the Accessibility requirements for ICT products and services (EN 301 549), developed by CEN, CENELEC, and ETSI, are proving instrumental in helping cooperative banks bring EAA requirements into practice. This standard serves as a valuable resource and should remain voluntary. It is helpful to note, however, that the different implementation dates for the EAA (2025) and the forthcoming standardized standard EN 301 549 (2026) in line with the requirements of the EAA can create added complexity. Clarifying its relationship with the Web Content Accessibility Guidelines (WCAG 2.1) would also enhance its utility.
Despite these challenges, cooperative banks remain strongly committed to embedding accessibility into the heart of their operations — and they continue to lead by example in making banking more inclusive for all.