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On April 23, 2026, the Dutch Authority for the Financial Markets (AFM) published its third European Accessibility Act (EAA) update, setting expectations for financial institutions regarding digital accessibility and announcing a compliance review. The AFM expects financial institutions to identify accessibility risks in their digital services and implement improvements that comply with Web Content Accessibility Guidelines (WCAG) criteria. Financial institutions must establish processes to ensure and monitor the accessibility of their websites, applications, and digital services. The WCAG framework defines three conformity levels: A (minimum), AA, and AAA (maximum). Under the EAA, financial institutions must comply with levels A and AA. The AFM's third EAA update provides practical guidance, including involving people with disabilities in the design phase of digital services. The AFM has noted that many financial institutions have submitted non-conformity notifications, demonstrating commitment to improving accessibility. However, the AFM observed that these notifications often lack specificity, making it difficult to assess the precise nature and location of accessibility problems. The third EAA update includes clarified instructions for completing the EAA notification form to address this issue. During the coming quarter, the AFM will conduct a compliance review examining the extent to which financial institutions' websites meet WCAG criteria, with particular focus on level-A criteria. The review will prioritise sectors and services most frequently used by consumers. Financial institutions may be contacted if non-compliance is identified. The update applies to advisers, intermediaries, banks, investment firms, pension administrators, credit providers, and insurers. REFERENCES: Dutch Authority for the Financial Markets (AFM), "EAA update 3 - AFM start nalevingsonderzoek en benadrukt belang van een duidelijke EAA-melding" (April 23, 2026)