Regulatory Alert: EU Accessibility Act with Compliance Deadline – 28 June 2025

The European Accessibility Act (EAA) and the national transposition laws (for example the German Barrierefreiheitsstärkungsgesetz – BFSG) will take effect on 28 June 2025, imposing broad accessibility requirements on product manufacturers, service providers, and retail distributors across the EU. These regulations aim to ensure full digital participation and accessibility of information, particularly for individuals with disabilities, creating a standardized, cross-industry legal framework.

Key Compliance Areas:

Businesses must ensure contract documents, websites, customer portals, product designs, and services are accessible. This includes:

✔ Digital accessibility for product information websites, customer portals, authentication & identification services but also for documents & emails containing information about a service or a product.
✔ Accessible customer interaction points, such as call centers and customer services.
✔ Technical compliance of documents (PDF/UA format for machine readability).
✔ Content to be presented in plain language for better comprehension, where applicable.

Non-compliance may result in fines, restrictions, or legal action at the national level.

Financial Services Impact:

The regulation explicitly requires financial service providers to make banking services accessible. This includes both technical adaptations and content simplifications, ensuring better accessibility for example in investment advice and related services. Despite the upcoming entry into force, the substantive scope of the regulation remains unclear in many aspects. One example: the required comprehensibility and accessibility of Key Information Documents (KIDs):

According to the EAA, the language used in such document must be understandable and must not exceed a B2 complexity level. But KIDs are already required to be written in clear, succinct, and comprehensible language (Art. 6(4)(c) of the PRIIPs Regulation). Since the content and structure of KIDs, including narratives, are strictly defined by the PRIIPs Regulation, it is reasonable to assume that KIDs should be considered B2-compliant.

But even If the B2 compliance assumption holds, what about the technical accessibility of the KIDs’ format? Does a KID have to be available in a text format that enable the generation of alternative assistive formats, allowing investors to access content through different presentation methods and sensory channels and would PDF/UA then be an acceptable format?

Similar questions arise for other mandatory documents, such as Final Terms. Some industry associations have submitted requests to the relevant authorities but in most cases, no responses have been received yet, and FAQs remain unpublished.

Next Steps: Albeit the unclear scope in various operational aspects, with the 2025 deadline approaching, companies operating in the EU should assess their accessibility strategies and prepare for compliance to avoid penalties and operational disruptions.