Banks and Fintech Companies Under New Guidelines from the Banking Act: Required Actions Immediately
The Barrier-Free Information Technology Ordinance (BFSG), set to come into force in June 2025, marks a significant step towards digital accessibility for all. This legislation will impact banks, fintechs, payment service providers, and other digital financial product providers, ushering in a new era of inclusivity.
The BFSG imposes binding accessibility requirements on digital financial services, including easy-to-understand language, accessible payment terminals, barrier-free authentication processes, and compliance with established accessibility standards.
Compliance with the BFSG entails several critical aspects. Providers must ensure their digital financial products and services adhere to accessibility standards, such as harmonized EU norms, DIN or ISO standards, and the Accessible Information Technology Ordinance. A conformity assessment is mandatory, often documented by a CE marking and an EU Declaration of Conformity issued by manufacturers or providers. Compliance monitoring by authorities includes regular inspections, with penalties such as fines up to 100,000 euros or sales bans for violations.
Digital financial platforms must use clear, user-friendly language, particularly on central webpages and communication channels, to help users with cognitive disabilities or limited language proficiency. Including alternative communication options, such as sign language or similar accessibility features, is necessary to support users with hearing impairments.
Payment interfaces and terminals must be physically and technically accessible, supporting users with disabilities through tactile keypads, screen readers, and voice guidance. Authentication procedures need to be barrier-free, allowing alternatives to biometrics or multi-factor methods that might be inaccessible to some users.
The ordinance allows economic operators to assess if meeting certain accessibility requirements would impose a disproportionate burden. Such assessments must be documented and, except for micro-enterprises, notified to the competent authority. Providers need to continuously review and update their digital services for accessibility compliance, reacting promptly to identified barriers and facilitating user feedback for iterative improvement.
When acquiring or developing digital financial services, providers are encouraged to use recognized standards such as the EN 301 549 (harmonized European standard for ICT accessibility) as a baseline for accessibility features.
Preparation for the BFSG can help secure legal standing and potentially tap into new customer groups. Companies should analyze their products and processes early on due to the vaguely formulated requirements of the BFSG that become more concrete through case law, DIN standards, and practical examples.
Industries like restaurants, retail, or self-checkout zones will also be affected, as payment terminals should have a connection option for headphones and be designed to be tactile, contrast-rich, and linguistically accessible in the future.
Dana Wondra, a seasoned professional in the field, has been at the forefront of this movement. With a background in business administration and marketing, she currently serves as the Senior Manager Marketing at Payment & Banking and, since June 2022, has been using her expertise as a consultant and project manager at GOLT Coaching. Her previous experience includes working at TOP Sportmarketing Berlin GmbH for almost two decades and playing a key role in public relations for the Olympic Training Center Berlin e.V. and organizing various Olympic campaigns.
In conclusion, the BFSG aims to make digital financial services accessible to all, ensuring clarity, usability, and security for everyone. By adhering to these requirements, providers can create a more inclusive financial landscape, benefiting both businesses and their customers.
The BFSG requires digital financial service providers to comply with accessibility standards like EN 301 549 and harmonized EU norms, DIN or ISO standards, and the Accessible Information Technology Ordinance. Compliance aspects include using clear language, providing alternative communication options, creating tactile and contrast-rich payment terminals, and ensuring barrier-free authentication processes.
Furthermore, the BFSG's impact extends beyond the digital financial sector, influencing industries like restaurants, retail, and self-checkout zones by mandating accessible payment terminals with options like headphone connections and tactile designs.
