Guide to Bank and Credit Union Website Accessibility

Greg Kihlström

Trying to find out exactly how to apply accessibility rules and standards to your financial institution’s website can be challenging. There are many sources of conflicting information out there that can make it difficult to understand the exact rules and how/when they apply to you.

We have reviewed the latest information to provide a guide that can help you as you plan your next site or revise your current one.

What Does Accessibility Mean?

The primary components that you need to take into account when making a site accessible can be put into four primary categories:

  1. Visual/Audio Content: Provide equivalent alternatives for images, videos, and audio content.
  2. Color: Don’t rely on color alone to communicate. Maintain high contrast between text and background colors.
  3. User Control: Give users control over navigating, scrolling and timed content. Provide tab controls where applicable. 
  4. Information Display: Ensure content can be understood without style sheets. Provide table headers to make tables easy to understand.

What are the Relevant Laws and Guidelines?

Below are the key standards, guidelines and laws that are typically involved in web accessibility:

  • Rehabilitation Act (1973)
    • Section 508 is part of the Rehabilitation Act, added in 1998 and specifically addresses website accessibility for federal agency websites.
  • Section 508
    • A series of standards within the Rehabilitation Act (1974) that provides three levels of compliance (levels A to AAA) of how to provide an accessible website.
  • Americans with Disabilities Act (ADA)
    • Relates more to the built environment than digital. Doesn’t specifically dictate standards for website accessibility. Despite this, a famous lawsuit against raised issues for all brands on the Web.
  • World Wide Web Consortium (W3C)
    • An international community that works together to develop web standards, including HTML, CSS, XML and WCAG.
  • Web Content Accessibility Guidelines (WCAG)
    • Accessibility standards initiated by W3C in the late 1990s. These guidelines outline 3 levels (A, AA, and AAA of accessibility compliance. We’re currently in version 2.0 of the WCAG.

What are the Levels of Website Accessibility Compliance?

How accessible is your site? The World Wide Web Consortium created the Web Content Accessibility Guidelines (WCAG) in order to allow people to measure their website’s level of accessibility. This measurement has (3) levels: A (Minimum Level of Compliance), AA, AAA (Maximum Level of Compliance). You can follow the link above to learn more of the specifics.

How does WCAG affect banks, credit unions, and other financial institutions?

Different industries and types of organizations are affected by web accessibility in different ways. As of January 18, 2018, federal agencies must comply with Section 508, and its recommendation of WCAG 2.0 Level “AA” compliance.

Title III of the ADA does not provide civil penalties for violations of the act but does permit private rights of action and allows individuals to bring enforcement actions and seek injunctive relief. 42 U.S.C. § 12188. Private companies are not required by law to be 508 compliant. Despite this, they can get into legal issues for not providing equal access to their customers. One example is that Target was sued (and settled for $6 million) in a class action lawsuit for not meeting the needs of blind users of

It is important to understand the implications of the Department of Justice’s recent settlement with Peapod, the nation’s largest grocery delivery service, based on the Americans with Disabilities Act (ADA). This settlement cites Title III of the ADA as justification for Peapod to provide a compliant site, and remediation requires it to achieve Level AA of the WCAG 2.0.  In the financial services sector nine credit unions in Virginia were sued in late 2017 for being inaccessible to handicapped users.

The DOJ was expected to announce a set of requirements for non-public sector websites which would affect banks sometime in 2018, but as of late 2017, it was announced that these recommendations would be moved to the “inactive” list of regulations for the time being. This creates a problem in that with a lack of specificity, commercial entities like banks may be subject to lawsuits for discrimination without any clear direction of what constitutes compliance with accessibility.

How do you adopt an accessible approach to your website?

Do you need help making your website compliant with WCAG 2.0 standards? There are a few things that you can do:

  • Review the WCAG 2.0 guidelines to have a good understanding of what will be required. Learn to understand the differences.
  • See where you stand with your current site by using accessibility checkers and assessment tools. There are several tools available ranging from basic free tools to more robust ones that are subscription-based.
  • Ensure compliance while you’re developing your new website by incorporating an accessible approach while planning and designing.  

There are tools that help you evaluate your site for accessibility, such as SiteImprove, or some other free online tools, which provides guidance on how to adhere to the various levels of WCAG 2.0 compliance.

While a lot of the heavy lifting to make a site compliant occurs during the design and development phases, if you have a Content Management System (CMS) and a lot of content contributors, it’s quite possible that non-compliant content could get entered. For instance, unless your CMS requires it, someone could add an image to your site without alternate text (otherwise known as “alt” text or tags). This will throw an error because WCAG guidelines require alternate text for any images.

Without specific guidance from the Department of Justice and the Americans with Disabilities Act, the best approach you can take with accessibility is to try for some type of compliance in order to risk legal action for discrimination. Assess your site to see where you currently fall according to the WCAG Guidelines and plan to meet at least Level “A” or “AA” compliance as soon as you can. Finally, if you’re planning a new website, you need to take accessibility into account.

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Greg Kihlström
Greg Kihlström
SVP Digital