Ensure clear accountability for safeguarding and monitoring digital accessibility
Executive Summary
AFM’s third EAA update makes clear that Dutch financial institutions must not only fix accessibility gaps, but also **assign clear internal accountability**, **embed accessibility compliance in governance and monitoring**, and **submit more specific non-compliance notifications**. AFM also announced a **sector-wide compliance review in the coming months**, with a focus on whether websites meet WCAG criteria, especially **level A** requirements, so compliance teams should treat this as an active supervisory campaign rather than routine guidance. #
What Changed
- - AFM expects financial institutions to identify accessibility risks in their digital services and implement improvements that meet the required WCAG criteria.
- AFM expects firms to embed and monitor accessibility through internal processes, rather than treating accessibility as a one-off remediation project.
- AFM is emphasizing clear accountability for safeguarding digital accessibility, which means firms should be able to show who owns accessibility compliance, monitoring, and remediation internally.
- AFM says EAA notifications of non-compliance must be more specific, because current submissions often do not describe the exact accessibility issues or where they are located.
- AFM has published further instructions on how to answer certain questions in the EAA notification form, indicating a stronger supervisory focus on the quality of regulatory reporting.
- AFM will conduct a compliance review of the sector in the coming months and will assess whether institutions’ websites comply with WCAG criteria, with specific attention to level A criteria.
Suggested Considerations
- Firms should map all consumer-facing digital services and identify which websites, apps, and digital documents fall within EAA/WCAG scope.
- Firms should assign a named internal owner for accessibility compliance, monitoring, remediation tracking, and regulatory notifications.
- Firms should document accessibility risks and remediation plans for each in-scope digital service, including the precise pages, functions, or documents affected.
- Firms should embed accessibility checks into design, development, testing, and change-management processes so compliance is monitored continuously.
- Firms should review EAA non-compliance notifications and make them more specific, including the exact accessibility issues, affected locations, and remediation status.
- Firms should verify WCAG conformance, with priority on level A criteria, for their highest-traffic consumer channels.
Key Dates
Compliance Impact
The compliance risk is material because AFM is moving from guidance to active review and may directly challenge firms with shortcomings. In practice, poor documentation, vague notifications, or weak governance can expose firms to supervisory intervention, remediation orders, and escalating scrutiny over the accessibility of consumer-facing channels.
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original AFM source before acting. Full disclaimer.
Summary
Financial institutions are working to make their digital services accessible. This is important, because it ensures that people with disabilities can manage their finances independently. To provide further guidance to the sector, the Autoriteit Financiële Markten (AFM) shares expectations and points of attention in the third EAA update. In the coming months, we will conduct a compliance review on accessibility. We encourage the sector to further refine their notifications of non compliance.