On 28 June 2025, the European Accessibility Act (EAA) introduced new accessibility requirements for a range of products and services across the European Union. The European Commission has given more information on its implementation.

Much of the focus in financial services has been on digital accessibility. Firms have reviewed their websites, apps and payment terminals to ensure that digital journeys meet the Web Content Accessibility Guidelines and other accessibility requirements, for example, making sure content is accessible to users of screen readers and other assistive technologies.

But the EAA also includes a requirement that directly concerns the clarity of content. For consumer banking services, information must be understandable, without exceeding a level of complexity above B2 of the Common European Framework of Reference for Languages (CEFR).

A document can therefore be technically accessible and still be difficult to understand.

B2 is widely recognised as a language proficiency level. In the Common European Framework of Reference for Languages developed by the Council of Europe, B2 is the higher “independent user” level. A B2 user can understand the main ideas of complex texts, including abstract topics and technical discussions in their field.

This creates a problem because the CEFR describes people’s language proficiency rather than the complexity of documents. Its B2 descriptors explain what users can understand and communicate. They do not define the characteristics that make a document B2.

In practice, organisations need to decide how they will assess complexity. Expert judgement, language tools and reader testing can all contribute.

The CEFR was not designed as a formula to certify a document as B2 compliant.

Financial information can be difficult to understand for many reasons, for example:

• Specialist vocabulary
• Long or complex sentences
• Dense information
• Abstract concepts
• Unclear terminology
• Poor structure or key information buried in detail
• Poor design and layout

The practical question is: can readers find the information they need, understand it and know what to do with it?

The Directive’s definition of consumer banking services includes:

• Certain credit agreements
• Investment services
• Payment services
• Services linked to payment accounts
• Electronic money

Not every document produced by a bank or financial institution automatically has to meet the B2 requirement under the EAA. Your legal and compliance team needs to assess what applies in your organisation and jurisdiction.

The EAA creates legal obligations within a defined scope. But the same comprehension problems occur across a much wider range of financial communications.

The same need for clarity extends to marketing, sales and customer-service communications.

For example, there are the communications that a customer receives before they sign an agreement, such as digital buying journeys, product summaries, brochures or informational content. There are servicing communications, such as letters or emails, renewal journeys or investment or insurance claims. These all have to combine regulatory accuracy, specialist terminology and the need to be understood.

Not all these documents are necessarily subject to the same EAA requirements. But they are part of the same customer experience.

Financial organisations can therefore address the content that falls within the regulatory scope while using the same work to improve customer communication more broadly.

The international standard for plain language provides a useful framework for addressing the clarity issues behind the B2 requirement. Part 1 of the standard, ISO 24495-1:2023, provides principles for developing plain language documents. Part 2 of the standard, ISO 24495-2:2025, applies the guidelines to legal communications, such as terms and conditions. This set of standards is a practical framework for turning the broad goal of understandable information into editorial choices.

The EAA provides a common European framework, but it is a Directive implemented through national legislation.

If your organisation operates in several countries, national implementing legislation and other relevant sector-specific rules also need to be checked locally.

Plain language experts have an important role to play once the requirements and priority content have been identified: making that information genuinely understandable.

For an international financial group, clear content cannot simply be translated word for word.

Sentence structure, financial terminology, conventions and reader expectations vary from one language to another. International groups need common clarity principles that can be adapted to each language and market.

For international groups, this makes local plain language expertise especially valuable.

A useful starting point is to identify the services concerned and map the relevant content. Which documents are regulatory priorities? Which are used most often? Which generate misunderstandings or repeated questions?

From there, teams can:

• Analyse the main sources of complexity
• Define shared writing principles
• Rewrite and test priority content
• Develop templates, guidelines and tools
• Localise and roll out the approach across languages and markets

This work usually involves legal, compliance, communications, marketing, digital and customer experience teams.

Stéphanie Guillaume is the founder and managing director of Avec des Mots, a French editorial communication agency specialising in plain language. She advises organisations on making complex information clearer and easier to use, through content strategy, rewriting, training and plain language programmes.

She is also behind Lisible, a French plain-language writing assistant. She is the French ambassador for the Plain Language Association International (PLAIN).

See Stéphanie Guillaume’s LinkedIn profile or visit the Avec des Mots website.