How the European Accessibility Act (EAA) impacts asset managers: What is the next right move?

What is the European Accessibility Act (EAA)? 

Through Directive (EU) 2019/882, the EAA aims to make products and services across the European Union more accessible to persons with disabilities. It covers a wide range of industries, including financial services, requiring that digital content such as KIDs distributed via websites and mobile applications be accessible to those with impaired vision, for example.
 

Non-compliance with EEA could mean restricted market distribution

As of the date of publication, it is still uncertain whether funds will fall under the scope of the EAA; the European Fund and Asset Management Association (EFAMA) challenged the European Commission (EC) on this, but no conclusive response has been provided as of yet. However, the general EC position is that it would not rule out funds from being subject to the EAA. In other words, the prudent approach for asset managers would be to proactively adhere to EAA while the bold approach would be to wait for further regulatory clarification.

Regardless of preferred approach, what is certain is there is a clear and present demand by distributors.

Indeed, distributors rely on asset managers to provide accessible documents to remain compliant with EAA standards. Article 4 of the EAA emphasizes the service provider’s responsibility in ensuring their services are accessible. Therefore, not providing EAA-compliant documents could lead to regulatory risks and restricted market access for distributors.

While the transition period extends until 2030, market-driven expectations will likely necessitate earlier adoption. Some distributors have decided to implement EAA immediately and are starting to demand EAA-compatible documents from fund managers. This puts significant pressure on asset managers to ensure all investor-facing documents, including KIDs, fund prospectuses, financial statements, and Sustainable Finance Disclosure Regulation (SFDR) disclosures, meet accessibility standards.
 

Key principles of accessibility

The EAA's accessibility obligations ensure that information in electronic forms adheres to the following principles, known as POUR:

• Perceivable: Information must be presented in ways that users can perceive, irrespective of their abilities.
• Operable: Interface components must be easy to operate.
• Understandable: Information and operation of the user interface must be clear.
• Robust: Content must be robust enough to be interpreted reliably by a wide variety of user agents (UAs), including assistive technologies.

These principles align directly with the Web Content Accessibility Guidelines (WCAG) 2.1 AA and are formalized within the harmonized European standard EN 301 549.

Key actions for compliance include:

• Ensuring KIDs are produced in PDF/UA or WCAG-compliant HTML.
• Applying proper structure, semantics, and alternative text.
• Validating compliance using accessibility testing tools.
   

Technical standards for document accessibility 

Asset managers will need to convert existing static PDF documents into accessible formats such as PDF/UA or WCAG-compliant HTML. This involves:

• EN 301 549 v3.2.1: The European standard for the accessibility of information and communication technology (ICT) products and services, referencing WCAG 2.1 AA compliance.
  • Clause 9.1.2.1 states: “Web content shall conform to WCAG 2.1 at level AA.”
• ISO 14289-1:2014 (PDF/UA): This standard specifies that “PDF documents shall comply with ISO 14289-1 (PDF/UA) to be considered accessible.”
   

The industry standard: PDF/UA and HTML

PDF/UA is expected to become the market standard for accessible KIDs due to its balance of branding, legal requirements, and accessibility. However, HTML versions may be required for better navigation and usability on digital platforms. Financial regulators are still evaluating the viability of HTML formats, with potential mandatory web-based disclosures.
 

Global trends in accessibility

The focus on digital accessibility is not limited to the EU. Other regions, including the UK, Australia, and the US, are increasingly adopting accessibility regulations for financial services. Asset managers distributing products across multiple jurisdictions may choose to align formats for operational consistency.
 

Takeaway

Asset managers should start preparing for compliance now—not only to adhere to prudent regulatory obligation, but also to meet the distributor demand for EAA-compliant fund documents. This preparation entails:

• Reviewing current document workflows
• Engaging with distributors early to align on accessibility expectations
• Ensuring the existing KIDs as well as new KIDs are EAA-compatible

Prioritizing EAA is crucial for asset managers to foster a more inclusive financial environment. By meeting these accessibility standards, asset managers can reach new investors reduce regulatory risks, and enhance reputational value.

For more detailed information, please refer to Annex I of Directive (EU) 2019/882 and EN 301 549 standards.
 

How Deloitte can help

Our KID & Fund Reports team is committed to helping asset managers comply with the European Accessibility Act (EAA). 

We do this by providing comprehensive gap analysis, producing or converting documents into accessible formats like PDF/UA and HTML, and offering consultation and training.

We can also help ensure that all investor-facing documents, other than KIDs (financial statements, prospectuses, etc.), meet regulatory and market-driven expectations, enabling smooth compliance for distributors and enhanced inclusivity for investors.