Accessible PDFs for banks and financial service providers
To a screen reader, an account statement is first and foremost a table. Consumer banking services are named explicitly in the European Accessibility Act, and the documents that go with them are almost always PDFs, generated automatically and in large numbers.
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General orientation, not legal advice. Which of your products and processes are in scope is a question for your legal and compliance teams.
All covered sectors side by side are in Affected industries, the legal basics in The European Accessibility Act and PDFs.
Which business is meant
Article 3(28) of Directive (EU) 2019/882 defines “consumer banking services” exhaustively. Austria adopted the definition in section 3(25) BaFG, Germany in section 2(24) BFSG. It covers the provision of the following services to consumers:
- credit agreements under the Consumer Credit Directive and the Mortgage Credit Directive (2014/17/EU),
- certain investment services under MiFID II (2014/65/EU), such as reception, transmission and execution of orders, portfolio management, investment advice and the safekeeping and administration of financial instruments,
- payment services under the Payment Services Directive (EU) 2015/2366,
- services linked to a payment account under the Payment Accounts Directive 2014/92/EU,
- electronic money under the E-Money Directive 2009/110/EC.
In retail banking that typically means current accounts, payments, consumer loans, mortgages and securities accounts. Insurance products are not included. ATMs and payment terminals are covered separately as products with their own requirements, which this page leaves aside.
Statements are tables
For every amount, a screen reader has to know whether it sits under the date, the booking text, debit or credit. That only works if the table is tagged as Table and the column headers are marked up as TH. Without that, the customer hears a string of numbers with no context. The relevant WCAG criteria are covered in WCAG for PDFs.
| Document | Characteristics | Common problems |
|---|---|---|
| Account statement, securities account statement | High-volume, tabular, often several pages | Untagged tables, missing column headers, amounts not linked to their column |
| Fee information document, price list | Standardised layout, many items | Tables as images, footnotes not linked |
| ESIS (European Standardised Information Sheet) | Prescribed structure for mortgage credit | Headings formatted only visually, reading order jumps |
| Credit agreement, account opening documents | Long, legally binding, often signed | No heading structure, form fields without labels |
| Key information document, product information | Prescribed length and structure | Charts without alternative text, multi-column layout in the wrong order |
Understandable up to level B2
Annex I Section IV of the directive adds duties for consumer banking on top of the general service requirements. Identification methods, electronic signatures, security and payment services must be perceivable, operable, understandable and robust. And information must be understandable without exceeding a level of complexity above level B2 (upper intermediate) of the Council of Europe's Common European Framework of Reference for Languages. In Austria this is in Annex 1 to the BaFG. In Germany, section 17(2) of the BFSGV covers it, with reference to information about how the banking service works.
So a perfectly tagged fact sheet written in dense legal jargon does not meet the requirement. Equally, the plainest text is of little use if a screen reader reads it out in the wrong order. You need both.
It gets awkward with mandatory disclosures that have a legally prescribed structure, such as the ESIS sheet or the standardised fee information document. You cannot rewrite those freely. You can add explanations, clear headings and a clean structure. How far the B2 requirement extends to texts like these has to be assessed case by case.
Start in output management
Nobody in a bank writes statements, notices and settlements in Word. They come out of output management and document composition systems, often in very large volumes. Post-processing individual files at that scale is hopeless. Accessibility has to come from the generator. We recommend this order:
- Find out whether the system can output tagged PDFs according to PDF/UA. Many systems have dedicated options or modules for this.
- Structure the templates: define headings, tables with header rows, lists, document title and language, and mark logos and decorative elements as artifacts.
- Check the fonts. Only embedded fonts with complete Unicode mapping can be read aloud and copied correctly.
- Check samples from production automatically so that regressions after template changes show up early.
- Sign off each document type once by hand, with a screen reader and PAC. The accessible PDF checklist helps.
Mailbox, file name, help desk
Statements and notices usually land in the electronic mailbox of online banking or the banking app. That mailbox is part of the website or app and must be usable in its own right. Download links need meaningful text (“Account statement March 2026, PDF” rather than “Download”), filters must work with a keyboard, and the sort order has to make sense.
A small detail with a big effect is the document title inside the PDF. If it is not set, many screen readers and PDF viewers show the file name instead, and that file name is something like “STMT_000123.pdf”.
Think about customer service as well. Someone who needs a document in another format has to be able to reach a person who can arrange it. Under the directive, support services such as help desks should provide information on accessibility through accessible means of communication.
What the API and retroactive tagging can do
Checks can sit directly in the document pipeline. With the EasyPDFUA API (Premium) you send a PDF via REST and get back a JSON result on tags, title, language, fonts and links. One option is a daily sample per document type that raises an alert when something looks off.
Retroactive tagging, on the other hand, is not worth it for statements from an output management system. EasyPDFUA adds a conservative base structure (paragraph tags, title, language, links, font and Unicode repair) but does not reconstruct tables. Already tagged and digitally signed PDFs are deliberately left alone, because any change would invalidate the signature. Tagging makes sense for individual legacy documents without a source, such as older information sheets. See Tag a PDF retroactively.
Dates that matter in banking
The requirements apply to services provided after 28 June 2025. Every statement and contract generated after that date is covered.
Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but no longer than 28 June 2030 (Article 32 of Directive 2019/882). That applies to the contract. Whether it also covers every document generated under it in future is an open question and has to be assessed case by case.
PDFs published on a website or app before 28 June 2025 and unchanged archive content are exempt. The microenterprise exemption for services hardly affects banks, though it may matter for small payment or e-money providers. Authorities and penalties are described in BaFG in Austria and BFSG in Germany.
Frequently asked questions
Which banking services fall under the EAA?
Consumer credit and mortgage credit agreements, certain investment services under MiFID II, payment services, services linked to a payment account and electronic money, in each case when provided to consumers. Insurance products are not included.
What does the B2 language level requirement mean?
Information about consumer banking services must not exceed the complexity of level B2 of the Common European Framework of Reference for Languages. It is a requirement on the content, not on the technical PDF structure.
Do account statements in PDF format have to be accessible?
Yes, if they are generated and provided digitally after 28 June 2025, because they are part of the payment account service. Properly tagged tables matter most.
Can EasyPDFUA make account statements accessible automatically?
Not fully. EasyPDFUA checks the structure and can add a conservative base structure, but it does not reconstruct tables and does not modify signed or already tagged PDFs. For high-volume documents, accessibility has to be built into the generation system.