5 reasons why the EU AI Act affects financial institutions’ digital accessibility

What is the EU AI Act? 

The EU AI Act is an EU regulation that sets out rules for the use of AI (artificial intelligence).

What is the timeline for The EU AI Act roll out?

The EU AI Act came into force on 1st August 2024.

Over a three year period, different areas of the Act are getting phased in. Originally, all areas were due to be enforceable by 1st August 2027, but a recent announcement has confirmed an extension to the 'high-risk AI systems' to 2 December 2027. 

The EU AI Act Newsletter #99 states:

"Notably, the proposal delays rules for high-risk AI systems to allow implementation guidance and standards preparation. MEPs introduce fixed application dates: 2 December 2027 for high-risk systems and 2 August 2028 for systems covered by EU sectoral safety legislation. Additionally, MEPs grant providers until 2 November 2026 for watermarking compliance." 

For more information, see the EU Artificial Intelligence Act Implementation Timeline.

Who does the EU AI Act apply to? 

It applies to any organisation that places AI systems on the EU market or uses them to serve people in the EU. 

The EU AI Act categorises AI into four main categories. These are: 

1. Prohibited AI practices: Considered dangerous or not inline with values and rights. 
2. High Risk: AI that can influence a person's life and decisions.  
3. Transparency Risk: Systems that generate content or interact with people, for example Chatbots.  
4. Low or No Risk: AI with little impact on an individual's life.

Note that General Purpose AI (GPAI) models such as Large Language Models (LLMs) may be being used within other tools. These models could fall under any risk category depending on how they are being used.  

It is number 2 above, High Risk, which is most significant for financial institutions, and below we outline why you need to consider the EU AI Act in the context of digital accessibility developments in your organisation.

5 reasons why the EU AI Act affects financial institutions’ digital accessibility

1. Accessibility is a legal requirement for high‑risk AI systems

The Act explicitly states that high‑risk AI systems must meet accessibility requirements, referencing existing EU accessibility legislation. Article 16 requires providers of high‑risk AI to ensure compliance with accessibility obligations set out in the European Accessibility Act (EAA) and the Web Accessibility Directive (WAD).

For financial institutions, this is critical because many AI systems used in customer‑facing services or decision‑making may fall into the “high‑risk” category, meaning accessibility is no longer optional or best practice, it is mandatory. 

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2. It strengthens and reinforces existing accessibility law

Unlike the European Accessibility Act, which is a Directive, the EU AI Act is a Regulation, meaning it applies directly and consistently across all EU member states without national variation.

For financial institutions operating across borders, or serving EU customers from outside the EU, this creates a clear, enforceable baseline that ties AI compliance directly to digital accessibility standards.

3. It can affect businesses outside of the EU, affecting UK‑based financial institutions

The EU AI Act applies to any organisation that places AI systems on the EU market or uses them to serve people in the EU, regardless of where the organisation is based.

This means UK‑based banks, insurers, and fintechs cannot treat accessibility in AI as an EU‑only issue. Therefore, AI‑driven digital services must be accessible if they impact EU customers.

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4. It raises the bar for AI‑powered customer journeys including disabled people

The EU AI Act is framed around protecting fundamental rights.

While several of the obligations under the Act are for high-risk AI providers, there are also obligations for providers of transparency and low risk systems that will improve customer journeys for all users, including disabled people and those classed as 'vulnerable' customers. 

For example, AI such as chatbots and automated decision systems, while they may not be considered high risk, they will still be subject to the requirements of Article 5 (1)(b) – this says that AI systems cannot exploit people’s vulnerabilities due to age, disability, or socio-economic situation where this could cause harm.

For financial institutions, this means ensuring AI-enabled customer journeys are: 

• Accessible to disabled and older users 
• Understandable and transparent 
• Designed to avoid bias, exclusion, or harm 

Accessibility therefore becomes a core part of AI design, procurement, and assurance, not a downstream fix. 

5. It signals a shift from reactive compliance to proactive design

The phased implementation of the EU AI Act gives organisations time to embed accessibility into AI governance, risk management, and product development processes.

For financial institutions, this is an opportunity to move beyond minimal compliance and treat accessible AI as a marker of quality, trust, and resilience, especially as AI use continues to expand across digital financial services.

How does the EU AI Act relate to the EAA?  

In Article 16 of the EU AI Act, the EAA and Web Accessibility Directive (WAD) are specifically mentioned:  

“Providers of high-risk AI systems shall: …(l) ensure that the high-risk AI system complies with accessibility requirements in accordance with Directives (EU) 2016/2102 and (EU) 2019/882.”  

This means that AI that is categorised as ‘high risk’ must meet certain accessibility standards.

The EU AI Act is one piece of a wider regulatory puzzle that includes the EAA and Consumer Duty, all pointing toward stronger expectations around accessible, fair digital experiences.

To manage risk and deliver good customer outcomes, organisations, especially in the financial sector, need to look at these requirements together, not in silos.