Banking & Financial Services Website Accessibility: Your Complete ADA Compliance Guide

1ADA Title III: Places of Public Accommodation

The Americans with Disabilities Act Title III applies to "places of public accommodation," and banks are explicitly listed as covered entities. Federal courts have consistently ruled that this extends to websites and digital services that provide access to these physical establishments.

22024 DOJ Final Rule on Web Accessibility

The Department of Justice's 2024 final rule formally establishes WCAG 2.1 Level AA as the technical standard for ADA compliance. While this rule specifically addresses state and local governments (Title II), it signals the DOJ's clear position on what constitutes an accessible website—and courts are likely to apply similar standards to private sector entities under Title III.

3Banking Regulators and Accessibility

Beyond ADA requirements, banking-specific regulators have signaled increased attention to digital accessibility:

• •OCC (Office of the Comptroller of the Currency) has issued guidance on fair access to financial services
• •CFPB (Consumer Financial Protection Bureau) examines accessibility as part of fair lending and UDAAP reviews
• •FDIC and Federal Reserve have incorporated digital accessibility into CRA (Community Reinvestment Act) considerations

4WCAG 2.1 Level AA: The Technical Standard

The Web Content Accessibility Guidelines (WCAG) provide the specific technical requirements for accessible websites. For a detailed comparison of versions, see our guide on WCAG 2.1 vs 2.2.

WCAG is organized around four principles—Perceivable, Operable, Understandable, and Robust (POUR). Each contains specific success criteria that websites must meet for Level AA compliance.

📝 Complex Forms and Applications

Loan applications, account opening forms, and fund transfer interfaces often contain dozens of fields with intricate validation rules. Common problems include:

• ✗Missing form labels — Fields identified only by placeholder text that disappears when typing
• ✗Unclear error messages — "Invalid input" without explaining what's wrong or how to fix it
• ✗Multi-step forms without progress indication — Users can't tell where they are in the process
• ✗Required field indicators that aren't accessible — Red asterisks without text alternatives

Learn more: How to Fix Common WCAG Failures

📊 Account Dashboards and Data Tables

Banking dashboards display critical financial information—account balances, transaction histories, investment portfolios. Common accessibility failures include:

• ✗Tables without proper headers — Transaction lists that screen readers can't interpret
• ✗Charts and graphs without text alternatives — Visual data representations that exclude blind users
• ✗Color-coded status indicators — Green/red indicators with no alternative for colorblind users
• ✗Dynamic content updates — Balance changes that aren't announced to screen readers

📄 PDF Statements and Documents

Monthly statements, tax documents, and account agreements are frequently provided as PDFs—and these documents are often completely inaccessible:

• ✗Scanned image PDFs — Statements that are just pictures of text, completely invisible to screen readers
• ✗Untagged PDFs — Documents without structure tags that define headings, tables, and lists
• ✗Poor reading order — Multi-column layouts where content is read in the wrong sequence
• ✗Missing document language — PDFs without language tags that affect screen reader pronunciation

🔐 Authentication and Security Features

Security is paramount in banking, but security features often create accessibility barriers:

• ✗Image-based CAPTCHA — Security challenges that blind users can't complete
• ✗Session timeouts without warning — Automatic logouts that don't give users time to extend
• ✗Virtual keyboards — On-screen keyboards for password entry that can't be operated with assistive technology
• ✗SMS-only two-factor authentication — No alternatives for users with hearing disabilities