Financial services products have accessibility challenges that go beyond the typical web product. Complex data tables, multi-step forms, authentication and identity verification flows, real-time market data, and document-heavy journeys all introduce specific WCAG failure modes that a generic accessibility consultant may not fully understand. The FCA Consumer Duty framework adds another layer. Here is how those things connect.
FCA Consumer Duty and accessibility
The FCA Consumer Duty, which came into force in July 2023, requires firms to deliver good outcomes for retail customers. The Consumer Understanding outcome explicitly includes making sure customers can access and understand the information they need to make informed decisions.
Disabled customers are disproportionately affected when digital products are inaccessible. A product that cannot be used by someone who navigates by keyboard, or cannot be read by someone using a screen reader, is not delivering a good outcome for those customers. While the Consumer Duty does not directly reference WCAG, inaccessible digital products are a material risk under the Duty.
Common accessibility failures in fintech products
Data tables. Investment dashboards, portfolio summaries, transaction histories, and rate comparison tables are often implemented without proper table markup. Screen reader users need column and row headers, proper scope attributes, and sometimes table captions to navigate a data table meaningfully.
Authentication flows. Identity verification steps that require drag-and-drop, image selection puzzles, or specific cognitive tests can fail WCAG 3.3.8 (Accessible Authentication). Multi-factor authentication that relies solely on a method that is inaccessible to some disabled users is also a concern.
Real-time data. Live exchange rates, portfolio value updates, and market feeds need to handle aria-live regions carefully. Too aggressive and they become noise; too passive and screen reader users miss key updates.
Multi-step forms. Onboarding journeys, KYC processes, and application forms in financial services are often long, complex, and spread across multiple steps. Error handling, field association, step progress indication, and session timeout handling all need explicit accessibility consideration.
Document accessibility. Key investor information documents, terms and conditions, statements, and contracts provided as PDFs need to meet PDF/UA requirements.
EAA and financial services
The European Accessibility Act covers digital banking services, including consumer-facing online banking, payment services, and e-money services. UK financial services organisations with EU customers need to assess their EAA obligations.
What a fintech accessibility engagement covers
I work with financial services products on:
- WCAG 2.1 and 2.2 AA audits of web applications and native mobile banking apps
- Data table, form, and authentication pattern review
- EAA readiness assessments for EU-facing products
- VPAT production for enterprise B2B sales
- FCA Consumer Duty digital accessibility risk assessment
- Developer training for finance-specific WCAG patterns