Accessibility and the Payment Industry – An SPA Position Paper – November 2025
- Regulatory Context
Across Europe, accessibility is becoming a defining feature of how products and services are designed, delivered, and experienced.
The European Union’s Directive (EU) 2019/882 on accessibility requirements for products and services (the EAA Directive) reflects a clear regulatory shift towards ensuring that all citizens, including persons with disabilities, can interact with essential products and services without barriers.
The Directive entered into force on 27 June 2019, with application starting on 28 June 2025. It expressly mentions consumer banking services, payment terminals, and certain self-service terminals such as ATMs, ticketing and check-in machines, and interactive self-service information terminals.
- Scope of the Directive
The EAA Directive primarily targets services and interfaces — such as apps, websites, and terminals — rather than physical products.
The physical payment card itself (e.g., its plastic design or tactile features) is not directly mentioned in the Directive and is therefore not an in-scope product.
However, since payment cards are used in the provision of payment services, they remain part of the broader accessibility ecosystem. Consequently, the services and devices that interact with cards must ensure accessibility in both digital and physical interfaces.
Financial institutions and payment service providers must ensure that:
- All digital and physical interfaces related to card usage are accessible; and
- Information and support related to card services are provided in accessible formats.
- National Implementation
While the Directive sets a common European framework, national transpositions may go further in scope and detail.
There might be discrepancies between Member States in the interpretation and implementation of the EAA Directive.
Stakeholders are therefore encouraged to consult national regulatory bodies to obtain guidance tailored to their jurisdiction and ensure alignment with local legal expectations.
- Industry Action: SPA Members’ Commitment
Regardless of the Directive’s scope, Smart Payment Association (SPA) members actively address the topic of accessibility across all products and services.
All SPA member companies have developed “accessible” products and continue to enhance their solutions to meet evolving expectations and regulatory requirements.
SPA members already provide a range of compliant and inclusive payment solutions, designed to support customers’ accessibility needs.
For example, payment cards with tactile cues such as notches, braille markings, and raised symbols, as well as visual enhancements like high-contrast designs and larger fonts for improved legibility, can be offered.
Each member company designs its own solutions and ensures that accessibility is embedded in its product development process.
- Beyond Compliance: Accessibility as Innovation
This evolution is not solely a matter of compliance. Accessibility enhances usability for all customers, reinforces trust, and positions brands as inclusive and socially responsible actors.
In the payments sector, inclusion means going beyond functional requirements to create intuitive, dignified, and frictionless experiences for every user.
Inclusion in payments is not a passing trend but a long-term driver of innovation and differentiation.
By aligning product development with emerging regulations and the values they represent, the payment industry can deliver solutions that are both legally compliant and socially transformative — ensuring that every transaction, for every person, is accessible by design.
