The verdict in three sentences
Since 28 June 2025, the European Accessibility Act (EAA) makes accessibility mandatory for consumer banking services, website and app included. For a digital bank or financial services firm in Brussels, compliance costs 20,000 to 80,000 EUR in 2026: a WCAG 2.1 AA audit of 4,000 to 12,000 EUR, then remediation of 15,000 to 65,000 EUR depending on technical debt. Waiting costs more than fixing, because national transposition laws allow regulators to impose fines and order corrections, and in France fines reach 50,000 EUR per non-compliant service.
What the EAA concretely requires from an online bank
The compliance officer of a Brussels-based fintech must cover the whole digital customer journey: account opening, login and strong customer authentication, transaction history, transfers, card management, e-signature, messaging and support. The technical reference is the European standard EN 301 549, which incorporates WCAG 2.1 level AA. Two deliverables are expected: a published accessibility statement explaining how the service meets requirements, and documented processes to keep it compliant over time. Belgium, being trilingual, adds a practical point: each language version (FR, NL, EN, sometimes DE) must be equally accessible.
| Requirement | Content | Common blocker in banking | Indicative 2026 effort |
|---|---|---|---|
| Perceivable | Contrast, text alternatives, captions | Spending charts with no alternative | Medium |
| Operable | Keyboard navigation, no blocking time limits | Session timeout without warning | Medium to high |
| Understandable | Clear labels, explicit error messages | Transfer forms with vague errors | Medium |
| Robust | Screen reader support (NVDA, VoiceOver) | Unlabelled custom JavaScript components | High |
| Strong authentication | Alternative to visual code or gesture | Captcha and randomized virtual keypad | High |
| Documents | Accessible PDF statements and contracts | Statements generated as image PDFs | Medium to high |
| Statement and processes | Publication, yearly update | Missing or outdated | Low |
Microenterprises (under 10 staff and under 2 million EUR turnover) are exempt for services, but a bank or fintech almost always exceeds these thresholds.
What compliance costs in 2026
The budget mostly depends on technical debt: a site and app built on a recent design system are quick to fix, while a front end layered since 2017 sometimes means rewriting whole components. Multilingual Belgian sites add 10 to 20 % for testing each language version.
| Item | 2026 range (EUR) | Indicative timeline | Note |
|---|---|---|---|
| WCAG 2.1 AA audit on a sample of 15 to 30 screens | 4,000 to 12,000 | 2 to 4 weeks | Web and mobile app audited separately |
| User testing with people with disabilities | 3,500 to 9,000 | 2 weeks | 5 to 8 participants |
| Design system and component fixes | 8,000 to 32,000 | 4 to 10 weeks | Buttons, modals, forms, tables |
| Critical journey fixes (onboarding, transfer, card) | 5,000 to 22,000 | 3 to 8 weeks | Top priority |
| Accessible PDFs (statements, contracts) | 2,000 to 10,000 | 2 to 4 weeks | Automatic tagged generation |
| Accessibility statement per language | 1,000 to 3,000 | 1 week | Yearly update |
| Product and dev team training | 1,500 to 4,500 | 2 to 3 days | Prevents regression |
| Indicative total | 20,000 to 80,000 (audit + fixes) | 3 to 6 months | Excluding automated CI tests |
Then plan a yearly re-audit of 2,000 to 5,000 EUR and automated tests in the deployment pipeline, which catch roughly 30 to 40 % of issues, the rest requiring manual testing.
Prioritize without freezing everything
The efficient method is to address journeys with the highest regulatory and commercial stakes first: onboarding, authentication, transfers. Next come shared design system components, where each fix spreads across dozens of screens. Editorial content (FAQ, blog, pricing pages) comes last, as it is simpler to fix. Publish an honest accessibility statement with the real compliance level and a timeline: regulators also assess the approach.
Mini case study
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Sophie, compliance officer at a 140-person fintech in Brussels, has 25 web screens and 20 mobile screens audited in French and Dutch for 10,500 EUR. Measured WCAG compliance is 54 %. The remediation plan is priced at 42,000 EUR: 20,000 EUR on the design system, 15,000 EUR on onboarding and transfer journeys, 7,000 EUR on PDF statements. With 3,500 EUR of training and 2,000 EUR for statements in two languages, the total reaches 58,000 EUR. On the other side, if 2 % of 4,000 monthly account applications drop out because of accessibility barriers, 80 customers a month are lost. At an estimated lifetime value of 400 EUR per customer, that is 32,000 EUR of value lost every month, so the project pays back in about 2 months, before even counting regulatory risk.
FAQ
Does the EAA apply to mobile banking apps?
Yes, the app is part of the consumer banking service and must meet the same WCAG 2.1 AA criteria. A separate mobile audit usually costs 3,000 to 7,000 EUR.
What does a non-compliant bank risk?
Penalties are set by each member state's transposition law and can include fines, correction orders and, in serious cases, withdrawal of the service. In France, fines reach 50,000 EUR per non-compliant service; check the Belgian enforcement rules with your counsel.
Do we need 100 % compliance immediately?
The legal target is compliance, but regulators also look at the trajectory. Moving from 50 % to 85 % in 6 months with a published plan is defensible, while having no statement at all is not.
Are automated tests enough?
No, they catch around 30 to 40 % of issues (contrast, missing attributes). Keyboard navigation, message consistency and real screen reader use require a manual audit of 4,000 to 12,000 EUR.
How long does full compliance take?
Expect 3 to 6 months for a mid-sized digital bank, audit included. Projects that involve a design system rebuild can extend to 9 months.
Let's scope your project. Tell us your critical journeys, front-end stack, languages and the date of your last audit: we will scope the audit, priority fixes and a 3 to 6 month timeline. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
