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DOJ Banking App Settlement Reveals 2024 Digital Accessibility Requirements

MarcusSeattle area
digital accessibilitydoj settlementmobile appsbankingwcag compliance
Crop faceless young diverse male and female colleagues using laptops and taking notes in planner while working together on new project
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A recent Department of Justice settlement with a major bank has established specific technical requirements for mobile app accessibility, providing concrete benchmarks for what "accessible" banking services must deliver in 2024. While the DOJ's Title III guidance has been building momentum around digital accessibility, this case gives us specific standards for ensuring disabled people can access essential banking services.

Screen Reader Compatibility Gets Specific

The settlement doesn't just say "make it work with screen readers"—it mandates compatibility with JAWS, NVDA, and VoiceOver across platforms. That's significant because it acknowledges the reality of how blind and visually impaired users actually navigate digital services. I've seen too many dev teams test with one screen reader and call it done, but users don't live in that simplified world.

The technical requirements also specify proper heading structures, meaningful alt text for all interactive elements, and programmatic focus management during navigation flows. These aren't revolutionary concepts, but seeing them codified in a federal settlement gives development teams the ammunition they need when arguing for proper implementation time to serve disabled customers effectively.

Voice Control Beyond Basic Commands

What caught my attention was the emphasis on voice control support that goes deeper than standard iOS/Android voice features. The settlement requires custom voice commands for banking-specific actions—transferring funds, paying bills, checking balances. This reflects the DOJ's understanding that disabled people need full access to banking workflows, not just basic functionality.

From a development perspective, this means building voice control into the application architecture from the ground up, not retrofitting it later. The Pacific ADA Center's mobile accessibility resources have been highlighting this gap for years—voice users need contextual commands that match their mental models of banking tasks.

Authentication That Actually Works

The authentication requirements deserve special attention because they address fundamental barriers many banks create for disabled customers. The settlement mandates multiple authentication pathways: traditional passwords, biometric options, and alternative methods for users who can't use standard approaches.

This is where I see most financial institutions struggling operationally. Their security teams understand the technical requirements, but they haven't thought through how disabled people actually use their services. A blind user might not be able to complete visual CAPTCHAs. Someone with motor disabilities might struggle with complex gesture-based authentication. The settlement essentially requires banks to offer equivalent security while ensuring disabled customers can actually access their accounts.

Implementation Reality Check

Here's what this means for development teams working on banking applications: you need dedicated accessibility testing throughout your sprint cycles, not just at the end. The settlement timeline suggests the DOJ expects these changes within 12–18 months, which is aggressive for major banking systems but reflects the urgency of providing equal access to essential services.

The operational challenge isn't just technical—it's organizational. Most banks I've worked with have accessibility expertise scattered across different teams. UX designers know some WCAG guidelines, developers understand technical implementation, but nobody owns the complete user experience for disabled customers. This settlement essentially requires banks to develop that integrated capability to serve all their customers effectively.

I've been thinking about how this connects to broader patterns in DOJ enforcement. They're not just looking for basic compliance anymore—they want evidence that organizations understand their disabled customers' actual workflows and have built systems to support them. That's a much higher bar than checking boxes on a WCAG audit, and it reflects a more sophisticated understanding of what equal access actually means.

What Other Industries Should Notice

While this settlement focuses on banking, the principles apply across digital services. The emphasis on voice control, multiple authentication pathways, and comprehensive screen reader support signals where federal accessibility enforcement is headed generally—toward ensuring disabled people can actually use digital services, not just technically access them.

The technical requirements also reflect a more sophisticated understanding of how people actually use assistive technology. Instead of generic "make it accessible" language, we're seeing specific compatibility requirements and user workflow considerations that center disabled people's real experiences.

For development teams in any industry, this settlement provides a practical roadmap for digital accessibility implementation. The DOJ isn't just saying "follow WCAG"—they're specifying exactly how WCAG principles should translate into real user experiences that serve disabled people effectively.

Moving Forward

The banking sector has always been conservative about digital changes, but federal settlements create urgency that internal accessibility advocates rarely achieve alone. Development teams now have clear requirements, specific timelines, and executive attention focused on serving disabled customers.

The question isn't whether other banks will face similar scrutiny—it's whether they'll proactively ensure their disabled customers can access essential banking services or wait for federal intervention. Given the technical complexity involved, waiting isn't really an option for organizations that want to serve all their customers effectively while avoiding significant remediation costs.

This settlement shows the DOJ understands the technical realities of mobile app accessibility and what disabled people actually need from banking services. Now it's up to development teams to build systems that actually serve disabled users as equal customers, not just pass automated testing tools.

About Marcus

Seattle-area accessibility consultant specializing in digital accessibility and web development. Former software engineer turned advocate for inclusive tech.

Specialization: Digital accessibility, WCAG, web development

View all articles by Marcus

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