What began as a countdown to the European Accessibility Act’s June 28, 2025 enforcement date is now turning into a broader compliance and governance story for QA and software testing teams across banking and financial services.
As firms serving EU customers move from preparation to implementation, accessibility is no longer being treated as a peripheral UX issue or a final-stage check.
It is becoming a documented, testable, auditable control point that increasingly sits alongside performance, security, and resilience within the software delivery lifecycle.
A growing push around global accessibility reporting, including the use of Voluntary Product Accessibility Templates (VPATs), is reinforcing that shift.
A VPAT is a standardised document used to report how accessible a software product is against standards such as WCAG and EN 301 549, effectively turning QA testing outcomes into formal compliance evidence.
In addition, there are the Accessibility Conformance Reports, which are pushing firms to demonstrate not just intent, but evidence.
Fredericka Argent
For QA leaders, the message is becoming clearer: if accessibility cannot be traced, tested and documented, it may not stand up under regulatory or procurement scrutiny.
The legal backdrop is explicit. Fredericka Argent, special counsel in the technology regulatory group at Covington in London, explained in a legal analysis that “the EAA imposes various obligations on technology and online service providers… to ensure that the products and services that they offer in the EU are made accessible to consumers with disabilities.”
She pointed out that providers’ “websites and mobile apps [must be] accessible, as well as [providing] accessible information via any support services they may offer.”
For banking and insurance QA teams, that means the scope of accessibility testing extends well beyond a mobile app interface or a website front end. It reaches into support journeys, documentation, ticketing systems, and any digital channel used to deliver services.
Accessibility must now be designed, built, and validated into every customer-facing journey, and it must be evidenced through testing artefacts that stand up to regulatory scrutiny.
Traceable accessibility testing
For all the discussion around regulation, the practical backbone remains technical. EN 301 549, which incorporates WCAG, has emerged as the key benchmark around which teams are being told to organise test plans and evidence trails.
Argent noted that “the Commission determined that EN 301 549 should be updated to bring it into alignment with the requirements of the EAA, rather than drafting a new standard from scratch.”
Even amid uncertainty over implementation, she said that “even if an organisation covered by the EAA cannot or chooses not to fully comply with this standard, it is a useful guide for identifying the technical requirements for achieving accessibility of products and services covered by the legislation.”
That is important for QA teams because the EAA is not simply asking firms to say they care about inclusive design. It is demanding a repeatable method for proving that accessibility has been addressed.
The regulation’s structure, in fact, mirrors aspects of EU product safety law. Argent warned that “entities in the product supply chain must… ensure that products placed on the EU market remain in conformity with the EAA.”
She added: “Where non-conformance is identified, these entities must ensure that ‘corrective measures’ are taken… or report the non-conformance to ‘competent national authorities’.”
“Accessibility is more than a regulatory imperative, it’s a business advantage.”
– Russell Webb
For testing teams in banks, insurers and fintechs, that raises the bar on traceability, release controls, and defect management.
Accessibility defects can no longer sit outside mainstream QA governance. They have to be tracked from requirement to remediation, with evidence capable of supporting internal reporting, client due diligence and, increasingly, formal accessibility disclosures.
That is where the growing focus on VPATs becomes relevant. As more firms look to standardise global accessibility reporting, QA teams are finding themselves closer to the centre of compliance documentation.
A VPAT may be framed as a reporting document, but in practice it rests on the underlying quality of the testing evidence behind it. In regulated sectors such as financial services, that turns accessibility reporting into a QA issue as much as a legal or procurement one.
Urgent compliance landscape
One complicating factor for internationally active banks and financial services firms is that EAA compliance is not entirely uniform across Europe.
Russell Webb, vice president for Europe at Level Access, pointed out that “each of the 27 EU Member States has implemented the EAA through its national legislation, which may include additional requirements or specific penalties.”
Meanwhile, Derrin Evers, senior solution consultant at Deque Europe, made a similar point. “Some countries, like Ireland, have already established their own regulations, while others, such as Belgium, have made slower progress,” he said.
Russell Webb
“This inconsistency means financial services providers need to track regulatory changes in each country to avoid potential penalties.”
That cross-border complexity matters for firms with multiple digital platforms, shared engineering teams, and regionally distributed customer bases.
Evers stressed that “the EAA doesn’t only affect EU-based businesses. It applies to non-EU companies providing financial services to customers in the EU.”
For financial institutions, he added, “the compliance process involves more than just ticking boxes,” and requires them to be “transparent about how their digital services comply with the EAA’s accessibility requirements, providing clear documentation and evidence of their adherence.”
His warning on enforcement was blunt: “The EAA requires that penalties be ‘effective, proportionate, and dissuasive’,” as he added that “the stakes are high, and financial institutions must act quickly to ensure compliance.”
Webb, meanwhile, cautioned that many firms were still behind as the deadline approached. “We are aware of a surprisingly large number of companies that have not even begun the process of taking action to ensure compliance,” he said.
Accessibility moves left
If the legal picture is sharpening, the operational response is also becoming more defined. One of the clearest themes across the accessibility debate is that QA teams are being pushed to move earlier and think more broadly.
The EAA, as one explainer put it, means software testing must now “prioritize accessibility at every stage of the software development lifecycle.”
That has practical implications for how banking and insurance teams define readiness, risk and release quality.
Test cases are expanding to include visual impairments, like colour blindness and low vision, auditory disabilities, motor impairments, cognitive disabilities, and seizure risks, while teams are being told to incorporate screen readers like NVDA or JAWS, magnification software, speech-to-text tools, and keyboard-only navigation testing.
Eric Portis
Eric Portis, senior developer experience engineer at Cloudinary,framed the shift in especially practical terms. “With the EAA’s deadline approaching, QA teams need to operationalise accessibility testing,” he said.
He also pushed for accessibility to be handled as a first-class engineering concern: “Accessibility shouldn’t be treated as a one-off audit right before launch. It needs to live in QA workflows, right alongside functional, performance, and security testing.”
That message lands clearly in financial services, where release processes are already tightly bound to evidencing controls.
If accessibility now belongs in the same operational category as other release-critical requirements, then defects tied to keyboard navigation, screen reader compatibility, captions or contrast can no longer be sidelined as cosmetic issues.
Portis argued that this wider lens is especially important for visual media. “While the EAA impacts many areas of accessibility, visual content presents unique testing challenges and opportunities,” he said.
“From images and icons to videos and layout, ensuring visual accessibility is essential, not just for compliance, but for inclusive digital experiences.”
He added that “QA teams should ensure cross-device compatibility, verifying that players function smoothly across desktops, tablets, and mobile devices while supporting assistive tools like screen readers and page zoom.”
And while automation can help, he stressed that “most importantly, accessibility features should be tested not just with automated tools but with real users who rely on assistive technologies. This is where the most meaningful insights are found.”
Over-reliance becomes a risk
That balance between automation and human-led testing has become one of the most important fault lines in the accessibility discussion.
Automation is clearly gaining ground. Earlier analysis noted that frameworks such as AXE, Wave, or Lighthouse are becoming more embedded in CI/CD pipelines, while Portis said AI tools can “automate and streamline the process” of auditing media for accessibility gaps and even help generate “first-pass descriptions for review.”
But across the sector, concerns remain that firms are leaning too heavily on tooling without the right expertise, user feedback loops, or escalation processes around accessibility defects.
Paul Hoffman, senior manager at Applause, said the data showed a clear gap: “There is a disconnect between prioritisation and delivery.” He added that although accessibility is often treated as a high priority, many companies remain underprepared, and only a small minority report having plentiful internal expertise and resources.
Rob Mason
He was particularly critical of the limits of current automation approaches. “Tool finds too many false positives,” he said, quoting the most common complaint among users dissatisfied with automated accessibility tools. Other concerns included: “Tool finds too many low severity issues,” and “Tool isn’t finding blockers.”
Rob Mason, chief technology officer at Applause, pointed to the same problem from a resourcing angle. “Sixty-eight percent of respondents reported lacking the expertise or resources needed to test for accessibility independently or on an ongoing basis,” he said.
Mason added: “Forty-eight percent of respondents don’t have or don’t know if they have processes in place to stop a product release with inaccessible features from going into production.”
His conclusion was that “automated and AI testing solutions can support internal efforts, but added investment in external expertise and user feedback, particularly from PWD, is essential.”
That matters especially in banking, where teams often assume governance is stronger than it really is. If organisations cannot confidently block inaccessible releases, then accessibility remains a stated priority rather than an embedded control.
User-centred testing
Another recurring weakness is the failure to involve people with disabilities directly in design and testing. That gap has become harder to defend as accessibility expectations mature.
Hoffman warned that “nearly a fifth of those who state that their organization practices inclusive design report that they do not directly engage with people with disabilities.”
Paul Hoffman
He added: “Developing any digital experience, particularly new AI-based features, requires the same level of input from persons with disabilities.”
His broader conclusion was that “organisations must invest in ensuring that diverse input is integrated across the entire product development lifecycle.”
Webb took a similar line on the testing model itself. “A comprehensive audit involves manual testing by experienced accessibility professionals. Ideally, this team of testers should include people with disabilities,” he said.
Portis also made the case that real-world validation is where accessibility efforts either hold up or fall short. “QA teams play a vital role in creating digital experiences that truly work for everyone,” he said, adding that “the EAA is a call to design with empathy.”
For financial institutions, that points to a wider evolution in QA practice. Accessibility testing is becoming more user-centred, more scenario-based, and more closely tied to lived experience rather than static checklist completion.
In sectors where customer trust and regulatory scrutiny are both high, that makes the quality of the testing approach just as important as the quality of the final product.
“The EAA is a call to design with empathy.”
– Eric Portis
For all the focus on fines, market bans and compliance deadlines, many of the strongest advocates are now trying to shift the discussion away from narrow legalism.
Webb said “creating accessible digital experiences is fast becoming a priority for organisations,” and added that “with 1.3 billion individuals living with disabilities worldwide, ensuring that digital interaction is available to all should be common business sense.”
He concluded that “accessibility is more than a regulatory imperative, it’s a business advantage.”
Portis pushed the point further. “Prioritising accessibility across design, development, and QA isn’t just about meeting legal requirements,” he said.
The EAA, in his view, “is about extending reach to more audiences, building brand trust and driving revenue. Ultimately, it’s about honouring the web’s core promise as a space where everyone can communicate, learn, and do business together.”
That broader framing is likely to resonate with financial services leaders trying to connect regulatory demands with commercial outcomes.
Better accessibility can reduce friction in onboarding, improve usability in digital channels, and strengthen trust among customers who increasingly expect inclusive design as standard.
For QA teams, though, the immediate implication is more operational: accessibility is moving from principle to proof.
As the EAA beds in and firms look to formalise how they communicate accessibility posture through mechanisms such as VPATs and conformance reporting, industry insiders agree the job of QA becomes more central, not less.
Accessibility must be continuously tested, documented, monitored and defended. In banking and insurance, that means the era of treating it as an optional extra is over. Or, as one insider put it, accessibility testing is now “a legal responsibility, not a discretionary feature.”
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