Regulatory context
Insurance services are covered by the EAA under the broader financial services category in Article 2. Online insurance platforms - whether selling directly or through comparison sites - must meet EN 301 549, which incorporates WCAG 2.1 Level AA. This applies to quote journeys, policy purchase flows, claims submission portals, account management, and all customer-facing documentation including policy wordings and certificates. The Insurance Distribution Directive (IDD, Directive 2016/97) also requires that product information be provided in a clear and comprehensible manner, which aligns with accessibility obligations. Comparison and aggregator sites that facilitate insurance purchases are also in scope as intermediaries providing access to financial services.
Common issues Lumi finds in insurance websites
Quote and application form accessibility
Insurance quote flows involve complex multi-step forms with conditional logic - vehicle details, property characteristics, medical history, or employment information. These forms frequently have missing labels, unclear error messages, poor field groupings, and inaccessible custom controls like dropdown selectors and toggle switches.
Policy document accessibility
Policy wordings, schedules, certificates of insurance, and key information documents are frequently published as scanned or untagged PDFs. Policyholders must be able to independently read and understand their coverage, exclusions, and claims procedures. All policy documents must have proper text, structure, reading order, and alt text for diagrams.
Claims portal and submission flows
Claims submission portals involve multi-step processes including incident description, document and photo uploads, witness details, and damage assessment tools. These flows frequently lack proper form labelling, progress indicators, and accessible file upload components. Claims tracking dashboards often use status indicators that rely on colour alone.
Comparison tool and results tables
Insurance comparison interfaces present multiple policy options side-by-side with coverage levels, excesses, pricing, and feature matrices. These comparison tables and cards frequently lack proper table markup, sortable column headers, and screen reader-compatible comparison mechanisms.
Risk assessment and calculator tools
Premium calculators, excess selectors, coverage sliders, and risk assessment tools use custom interactive components - range sliders, interactive diagrams, and dynamic pricing displays - that rarely have keyboard support or screen reader announcements for value changes.
Renewal and account management interfaces
Policy renewal flows, mid-term adjustments, payment management, and no-claims discount tracking involve complex account interfaces. Auto-renewal notices, payment schedule changes, and policy amendment confirmations must be clearly communicated to all users through accessible notifications.
Insurance-specific challenges
Insurance digital services face accessibility challenges stemming from the complexity of insurance products and regulatory documentation. Quote journeys are long and conditional - a motor insurance quote may involve 30+ fields with branching logic based on previous answers. Policy documents are dense legal texts that need clear structure and navigation. Claims processes are stressful, time-sensitive, and require document uploads and detailed descriptions that must be accessible under pressure. Third-party comparison and aggregator sites add another layer where accessibility must be maintained across the distribution chain. Insurers also face the challenge of making actuarial information, risk disclosures, and regulatory-mandated documents (IPIDs, KIDs) accessible alongside the core purchasing journey.
Compliance timeline
The EAA is enforceable from 28 June 2025 for new insurance services offered digitally. Existing digital services have until 28 June 2030 to comply under transitional provisions. The IDD already requires clear and comprehensible product information, and national regulators are increasingly interpreting this to include digital accessibility. Insurers selling cross-border within the EU face enforcement in each member state where they offer services.
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Frequently asked questions
Does the EAA apply to insurance websites?
Yes. Insurance falls within the financial services scope of the EAA. Online insurance platforms, quote engines, policy management portals, and claims systems must meet EN 301 549 accessibility requirements. This applies to insurers, brokers, and comparison sites operating in the EU market.
Do insurance policy documents need to be accessible?
Yes. Policy wordings, certificates, key information documents (KIDs), and insurance product information documents (IPIDs) must be accessible. This means properly structured digital documents - not scanned PDFs - with correct reading order, tagged headings, and alt text for any diagrams or tables.
Are insurance comparison sites covered by the EAA?
Yes. Comparison and aggregator sites that facilitate the purchase of insurance products are in scope as intermediaries providing access to financial services. The entire comparison and purchase journey must be accessible, from search and filtering through quote comparison to policy purchase.
What accessibility standards apply to insurance claims portals?
EN 301 549 incorporating WCAG 2.1 Level AA applies to all web-based claims interfaces. The entire claims journey must be accessible - from initial notification and evidence submission through claims tracking and settlement communication.
Related resources
Last reviewed: April 2026. Content is reviewed quarterly for accuracy.