From point‑in‑time audits to living data: how banks can manage accessibility at scale

Stephen Cluskey & Noelle Daly

When the European Accessibility Act (EAA) came into force on 28 June 2025, banks were understandably focused on what it meant for their digital products and services. The Act, which is designed to make key digital services across the EU more accessible and affordable for people with disabilities, zeroes in on things like ATMs, online banking, payment terminals and ticketing and transport services. If a digital service plays a central role in how people live, work or communicate, the EAA aims to ensure it’s designed so that as many people as possible can use it fully and independently.

What’s less obvious at first is the EAA’s link to the built environment. While the Act doesn’t directly regulate building design, its annex does set expectations for the physical spaces where these digital services are provided—places like bank branches, stations, retail environments and public offices—ensuring that people with disabilities can access these services in practice. After all, an accessible ATM is of limited value if a step at the entrance means some customers cannot reach it.

Beyond complying with new accessibility legislation, financial institutions in the EU and elsewhere have recognised that inclusive banking builds trust, deepens customer loyalty and sets them apart in a competitive market.

But creating truly accessible banking experiences goes beyond basic compliance. It’s about more than ramps and signage. It’s about delivering dignity, privacy and ease at every interaction— whether that’s entering a branch, using a self‑service terminal, speaking with staff or queuing comfortably. 

Financial institutions may understand the importance of creating accessible, welcoming physical environments, but many struggle to make their physical spaces as accessible as their digital services. The question they’re asking now is not just “are we compliant” but “how do we enhance and manage accessibility across hundreds or thousands of locations in a consistent, measurable way?” 

Digital tools for assessing accessibility in the built environment have started to change the answer.

From local opinions to consistent standards

Traditionally, the best route for auditing the accessibility of the built environment was to engage a local consultant. For banks, that meant hiring a local expert who understood national or regional legislation, asking them to visit a handful of sites, and waiting for a report. 

On its own, that isn’t a bad approach. Local knowledge matters, and lived experience can be invaluable. But the wider a bank’s portfolio of buildings, the clearer the limitations become.

Each country has its own legislation and codes. Each consultant brings their own professional background and interpretation of those regulations.

Individually, none of that is inherently problematic or unprofessional. But with a variety of consultants across geographies, report templates will differ, language will vary and the level of detail will be inconsistent. The result is a collection of documents that are difficult to compare and almost impossible to stitch together into a global view. A global financial institution could easily end up with hundreds of PDF reports on various sites, each reflecting a different interpretation of what “good” looks like. It might be enough to fix issues in an individual branch, but it isn’t a robust basis for setting global standards or managing accessibility as an ongoing responsibility.

Digital platforms for evaluating built environments approach the challenge differently. Instead of starting with narrative reports, they start with structured, standardised criteria—often framed as clear, binary questions supported by photo evidence and measurements.

Is there step‑free access to the main entrance?
Is there adequate turning space at the ATM for a wheelchair user?
Is there seating available near the queuing area?

The same questions, in the same format, are asked in every branch, in every region. Because they are designed to serve customers around the globe, digital evaluation tools rely on best-in-class standards rather than the minimum requirements laid out by local code. With the data captured in a consistent way, corporate leaders can compare a flagship office in a financial centre with a small community branch in a historic building and have confidence that they are looking at like‑for‑like information.

With a common foundation, banks have a way to set accessibility standards that are truly global and understand how each of their buildings measures up, regardless of who collected the data.

Turning assessments into on‑the‑ground education

Another benefit of digital tools for assessing accessibility is that they double as powerful education tools for people working in branches every day.

We were once in a branch where the manager was walking through an assessment on a tablet, reading the questions aloud as she moved around the space. One question asked whether there was glare on the ATM screen. Before she could answer, three customers in the queue—all wearing glasses—spoke up, saying that the glare did make the screen difficult to read.

During the same assessment, a simple question about seating—“is there somewhere for customers to sit while they wait?”—came to life in a very human way. An older man with a walking cane came in to wait while his wife went to find parking. Because there was a seat available, he could sit comfortably and wait.

Witnessing the everyday effects of the ATM screen and that chair on customers helped the manager understand the human impact of accessibility requirements.

When branch teams carry out structured evaluations themselves, they learn about their buildings as they go and start to connect the checklist with real people. They see the effect of small changes—not only for people with disabilities but for parents with small children, older customers and others. Accessibility stops being something imposed from head office and becomes part of how branches think about serving their communities.

Digital tools can reinforce this learning by presenting assessment results both in a structured report and through an interactive platform, making the outcomes easy to understand and act on. On-the-ground consultants often spend a number of days writing detailed reports. In addition to the cost, the downside of this approach is that the report is often alienating because it’s difficult for bank leaders to understand the technical language, sift through the results, and act quickly on the recommendations.

With a digital assessment tool, local teams can manage accessibility themselves, following a clear list of actions in an interactive platform that allows them to track progress as they go.

Budgeting for quick wins and long‑term change

Improving the accessibility of the built environment can range from low‑cost adjustments to major capital projects. One of the most pragmatic advantages of a digital, data‑driven approach is that it helps banks tell the difference—and budget accordingly.

Instead of a spreadsheet that someone has to decipher, leaders can see—at a glance—the mix of quick wins and longer‑term projects within a building and across their real estate portfolio. That makes it easier to build realistic budgets, sequence work over several years and demonstrate that decisions are being made fairly and transparently.

A lot of common accessibility barriers are surprisingly easy to fix once they’re identified and documented. 

For instance, in one building we visited, the main entrance was a large glass façade. Our colleague with a visual impairment walked up and down in front of the building, unable to tell where the door was because there were no decals or markings to distinguish it from the surrounding glass panels.

That kind of barrier is relatively simple to address once it has been captured clearly and flagged to the right team. The same is often true of issues like glare on ATM screens, which can sometimes be resolved by adjusting overhead lighting or repositioning terminals.

At the other end of the scale are bigger investments: installing lifts, redesigning toilets, widening doorways or reconfiguring circulation routes. These changes require planning, budget and time.

Digital platforms for evaluating the built environment can help leaders and property teams prioritise by presenting data through a practical lens: which improvements are low cost and high impact, which are essential for safety and regulatory compliance, and which can be aligned with planned refurbishments.

A live, global picture rather than a one-off report

Perhaps the biggest benefit of using digital tools for evaluating accessibility is that they transform an accessibility assessment from a point‑in‑time audit to a living document. 

With the traditional approach, an accessibility audit is an event. A consultant visits, takes measurements, writes a report, and, for a while, everyone feels reassured. Then time passes. Furniture moves. Branch layouts change. Standards evolve. The report, quietly, falls out of date —as do the features of the building—until another assessment is commissioned.

A digital approach allows banks to treat accessibility more like other managed risks. A single dashboard enables leaders to see which branches have been assessed, how they perform against standards, what recommendations have been implemented and what gaps remain.

Crucially, an interactive platform means that this information can be updated as buildings change, so accessibility stops being a static score and becomes a dynamic picture of progress.

For senior leaders, this matters. It means accessibility data can sit alongside other key indicators in board meetings and stakeholder reporting, making it easier for financial institutions to show progress towards their ESG commitments with tangible action.

Managing accessibility with the same discipline as other risks

For any financial institution operating in the EU, the EAA has undoubtedly sharpened the focus on accessibility. But compliance with any single piece of legislation is only part of the story.

For banks, the real opportunity—and the real risk—lies in how accessibility is managed day to day across complex, distributed estates. That requires moving beyond ad‑hoc audits and fragmented reports to something more consistent, objective and scalable.

Digital tools for assessing accessibility in the built environment are not a silver bullet. They still rely on people asking the right questions and acting on what they find. But they do offer banks a way to:

• apply consistent standards across borders
• turn assessments into meaningful learning for branch teams
• prioritise budgets based on clear, comparable data
• and maintain a live, global picture of where they stand

In other words, they make accessibility manageable at scale.

As banks continue to invest in digital innovation, payments modernisation and customer journeys, it is worth asking a simple question: do we have the same level of visibility and discipline when it comes to the physical spaces where those journeys begin?

If the answer is no, now is the time for them to bring accessibility into the same data‑driven, continuous improvement cycle that underpins the rest of their business. In doing so, they will build trust, reduce risk and create banking experiences that work for everyone.