Banking services

93 1.0) rather than WCAG 2.0.

If a company would like to make the website compliant with a national legislation different from the local one (i.e. a Spanish company that have to make their website, already compliant with UNE 139803:2004¹³⁵ , also with (voluntary) Italian Stanca Law requirements), would have to face 400 EUR (1 working day according to Technosite) extra in order to learn how to apply the norms (web developers need 133 working days to make a website compliant with WCAG 1.0 vs. 134 working days if compliant with UNE, which is based on WCAG 1.0).

Therefore, in order to make one website compliant with the other “X” EU Web accessibility laws, a company must add 10,400 EUR to the 56,433.15 EUR that costs WCAG 1.0 AA (please note that this is an estimate and it has been assumed that all national legislations are based on WCAG 1.0 AA with slightly differences).

In what concerns barriers for business, it should be noted that retail services are a key intermediary factor in the modern economy acting as the conduit between thousands of good and service suppliers and consumers. Many consumers in Europe benefit from the EU integrated retail market by buying goods from other Member States. The retail sector is also one of the biggest users of Information and Communications Technology (ICT) when considering its role with eCommerce, and thus a driver of innovation. It has a major part to play in the sustainability of small businesses¹³⁶ and it also allows citizens to face the current economic downturn by giving them easy access to affordable and good quality consumables¹³⁷ due to the cutting costs of intermediation and stocking. These are among the reasons, why an increasing number of eCommerce businesses are providing accessible websites and services on a voluntary basis.

Retailers that use eCommerce operations should – ideally – give website visitors a good online shopping experience by way of easy navigation, fast loading web pages and secure, easy-to-use online payment gateways. Website visitors should have the opportunity to browse a catalogue, search for goods and services, add items in their shopping carts, manage the shopping cart and then proceed to check-out in order to end their order. It is also important that the user is able to communicate with the e-shop management.

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Consumers benefit through the use of websites, since it enables the collection and comparison of eventually scarce information, in particular online banking facilitates the consumers’

efforts to take care of their financial matters. This increases consumer confidence and saves time and thus, societal life is not thinkable anymore without websites anymore.

Online banking consists of three main parts: the marketing / information pages, the online application and the transactional banking area, all of these can provide the user with problems:

- Inconsistent navigation and page layouts;

- On-site search engines that don't find information, even when it is available;

- Bank orientated language that is not explained;

- Poor feedback when using interactive tools and forms;

- Inability to save an application and complete is at a later date;

- Too many steps in transactions and no visibility of progress;

- Unhelpful error messages; and

- Pages which are inaccessible to assistive technology.

The specific accessibility requirements for banking service websites can be classified into the following groups¹³⁹, most of them related with visual and cognitive impairments. The requirements for the websites transactional area, not included here in detail, should be aligned with the new Regulation on electronic identification and trust services for electronic transactions in the internal market¹⁴⁰.

• Web page template: having an application to generate web content makes publication simple and easy to define. This means that there is a page-model (template) where there will always be similar content where the only differences are the name, description, images, options (for example, Related items) displayed for the chosen item. For the web page template, the recommendations will be the same as those for a simple web page, referring to the WCAG 2.0 Guidelines. These are a set of rules with an international scope in order to agree on the development of accessible websites.

This is very helpful for all kind of disabilities, but especially for people with visual and cognitive impairments.

• Website sections and service presentation: web solutions usually organise navigation in sections. Every section has a description and can contain other sections and/or services. Users who rely on screen readers to obtain the information due to visual impairments often do not have the same ability to access the information as someone who is sighted. In order to ensure web accessibility of the website sections and the presentation of the good/service, the online banking application developer needs to:

o Make a clear navigation structure for the section, using list elements.

o In a web page that contains a list of sections, make the text used in the links unique and clear to describe each section.

139 Web Page Template. (2007). http://juicystudio.com/article/eshop-accessibility.php#webtemplate

140 COM (2012) 238

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o Data tables for services listings: when users with assistive technologies browse a web page, they must understand the services' details, and must be able to interact with the content. For example, with an inaccessible services listing, the user might not be able to select services options, or determine its price, or other problems that might make it impossible to continue using the website. A set of information about a service requires a data table because the navigation of the data table allows the user to retrieve the heading information.

o Use explicit label associations and clear text inside button images: When a user interacts with the services in order to select one of them. Every form element needs to have a label and this label must be explicitly associated.

o One must be careful with the use of colour or text decoration to provide information. It is important to remember that all information should be available without relying on the use of colour. Otherwise, colour blind people or people with some kind of cognitive impairment would be undermined.

o There must be clear information about prices, offers, etc. Some visitors can have learning disabilities and we must ensure that information about prices and offers are clear. Moreover the use of pictograms is highly recommended for people with cognitive impairments.

o The use of an accessible document format for documentation is necessary.

Some services include technical specifications - usually made available in PDF format. To ensure that all users can read the content of this documentation it is important that PDFs are accessible.

By the end of 2010, the number of banks in the EU had fallen by 2.2% to 6,825. 5,404 of which were banks based in the Euro zone. Bank branches also registered a decline of 1.9%, to 215,000, on the account of a rise in popularity of online banking.141 Hence, the number of EU27 banking service websites is assumed to be 6,825,

Most banks also have physical facilities (agencies/branches), the accessibility of these facilities (built environment) is mostly regulated through national building regulations/plans.

In some cases it is specified that they are applicable to the banking sector.

The number of Member States with accessibility requirements on private sector websites and ATMs has already been pointed out above. 11 EU Member States with specific accessibility requirements for banks have been evidenced as part of CEN/CENELEC/AENOR research under Mandate 420. ANED identified general obligations for the built environment of banks in 10 additional EU Member States.

The estimated turnover of architect services in Europe in 2006 was 37.74 EURb. With regard to banking services facilities, the number of banks (including the ones based in the Euro zone) and the number of bank branches has been pointed out above. The number of bank branches in the EU will be further used to calculate potential costs for architect service providers.

The regulatory landscape in the EU regarding ATMs and private sector websites had been described in detail in previous specifically dedicated sections. The CEN/CENELEC/AENOR

141 http://www.ebf-fbe.eu/uploads/Facts%20&%20Figures%202011.pdf

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Mandate 420 report¹⁴² provides a broad view on the legislative coverage of various accessibility issues in the built environment in different European countries and regions. The report identifies specific accessibility requirements for banking service facilities in 11 EU Member States (Austria, Belgium, Cyprus, Denmark, Finland, Greece, the Netherlands, Portugal, Spain, Sweden and the United Kingdom) out of 15 EU Member States covered by the analysis.

Regulatory differences in accessibility technical requirements in ATMs, private sector websites and the built environment in the banking sector lead to obstacles for both industry and consumers and create barriers to the free movement of goods and services.