Financial Services Accessibility & Privacy

Financial institutions face comprehensive digital compliance requirements including accessibility under the ADA and privacy under GLBA, state laws, and emerging regulations. Equal access to financial services is essential for economic participation.

High Enforcement Sector

Banks are expressly listed as "places of public accommodation" under ADA Title III. The CFPB, DOJ, and state regulators actively enforce both accessibility and privacy requirements for financial services.

Why Financial Accessibility Matters

61 Million

Americans with disabilities need accessible financial services

78%

of Americans use mobile banking apps regularly

$490B

annual disposable income of people with disabilities

Applicable Laws & Regulations

Banks, credit unions, and financial services are expressly listed as "places of public accommodation." Courts consistently apply website accessibility requirements:

  • Websites must be accessible to people with disabilities
  • Mobile banking apps must work with screen readers
  • ATMs must have audio and tactile accessibility features
  • WCAG 2.1 Level AA is the practical compliance standard
Learn About ADA Title III

The Gramm-Leach-Bliley Act requires financial institutions to:

  • Provide privacy notices explaining data collection and sharing
  • Allow customers to opt out of certain data sharing
  • Implement safeguards to protect customer information
  • Have written information security programs

FTC Safeguards Rule (updated 2023): Requires risk assessments, access controls, encryption, and incident response plans.

Financial institutions must comply with state privacy laws including:

  • CCPA/CPRA (California): Consumer rights to access, delete, opt-out
  • NYDFS Cybersecurity Regulation: Comprehensive security requirements
  • State data breach notification laws: All 50 states
  • State consumer protection laws: Unfair/deceptive practices
View State Privacy Laws

The Consumer Financial Protection Bureau and banking regulators enforce accessibility and privacy:

  • CFPB: Consumer complaint database, enforcement actions
  • OCC: Guidance on digital accessibility for national banks
  • FDIC: Consumer compliance examinations
  • NCUA: Credit union accessibility requirements

Critical Digital Touchpoints

Online Banking
Accessibility Requirements:
  • Screen reader compatible login
  • Keyboard navigable account dashboard
  • Accessible bill pay and transfers
  • Clear transaction history tables
  • Accessible statement downloads (PDF/HTML)
Privacy Requirements:
  • Secure session management
  • Privacy notice accessibility
  • Opt-out mechanism availability
Mobile Banking Apps
Accessibility Requirements:
  • VoiceOver (iOS) compatibility
  • TalkBack (Android) compatibility
  • Touch target sizing (44x44 minimum)
  • Accessible check deposit functionality
  • Biometric alternatives for authentication
Privacy Requirements:
  • App permissions transparency
  • Data collection disclosures
  • Secure data transmission
Account Applications
  • Credit card applications
  • Loan and mortgage applications
  • Account opening forms
  • Insurance quotes and applications
  • Investment account setup
Critical: If a customer cannot complete an application independently due to accessibility barriers, this creates discrimination liability.
ATMs & Kiosks

ADA Standards for Accessible Design require:

  • Audio output with headphone jack
  • Tactile input (Braille, raised buttons)
  • Accessible height and reach
  • Privacy for audio output
  • Large print display options
  • Timeout extensions

Security vs. Accessibility Balance

Financial institutions often struggle with balancing security requirements with accessibility. There are accessible alternatives for common security measures:

Security Measure Accessibility Issue Accessible Alternative
Image CAPTCHA Not accessible to blind users Audio CAPTCHA, logic puzzles, invisible reCAPTCHA
Time-limited sessions May not provide enough time Warning before timeout, ability to extend
SMS 2FA codes May be difficult for some users Authenticator apps, email codes, hardware keys
Fingerprint only Not usable by some users Multiple biometric options, PIN backup
Security questions Cognitive burden Allow password manager paste, simpler alternatives

Fintech & Digital-First Banks

Digital-only financial services face the same requirements as traditional banks:

Covered Entities
  • Neobanks and challenger banks
  • Payment apps (Venmo, Cash App, etc.)
  • Cryptocurrency exchanges
  • Lending platforms
  • Investment apps
  • Buy-now-pay-later services
Common Gaps
  • Mobile-only services without web alternatives
  • Gesture-dependent interfaces
  • QR code-only payments
  • Real-time trading without accessibility
  • Chat-only customer support

Notable Enforcement Actions

Institution Issue Outcome
Major National Bank Inaccessible online banking, mobile app $2.5M settlement, remediation required
Credit Card Company Application forms not screen reader accessible DOJ settlement, WCAG 2.1 AA compliance
Insurance Company Quote system keyboard inaccessible $500K settlement, accessibility coordinator
Credit Union Member portal accessibility barriers Private settlement, 18-month remediation

Compliance Checklist

Accessibility
Privacy
Enforcement Risk

HIGH

Banks are expressly covered by ADA Title III and face active regulatory oversight

Key Regulators
  • DOJ: ADA enforcement
  • CFPB: Consumer protection
  • FTC: GLBA Safeguards Rule
  • OCC/FDIC: Bank exams
  • State AGs: Privacy enforcement
Related Resources