The National Confederation of Persons with Disabilities (ESAMEA) has denounced serious and widespread accessibility problems in banking services, both digital and physical, in an official letter of protest to the Hellenic Union of Banks (EETT).

Despite individual improvements, which have been observed in some cases, the overall picture still creates conditions of exclusion, dependence on third parties, and violation of the autonomy, dignity, and personal data of people with disabilities, the letter said, conveying the complaints of its members.

ESAMEA, as a tertiary social and trade union body of persons with disabilities and officially recognized Social Partner of the State on disability issues, stresses in the letter that this situation is in direct contradiction with the country’s obligations under the United Nations Convention on the Rights of Persons with Disabilities, which Greece has ratified with Law 4074/2012, as well as with the provisions of the European Accessibility Act (Law 4994/2022).

Focus on people with visual disabilities

Particular reference is made to the problems faced by people with visual disabilities, starting with mobile banking applications. According to the complaints, many mobile banking apps have serious accessibility shortcomings, as they are not fully compatible with screen reader software such as VoiceOver and TalkBack. Basic functions – payments, transfers, balance checking, and card management – are often rendered impossible without the assistance of a third party, and alternative means of support are absent.

Significant issues are also identified in the operation of ATMs. While recognising the progress made with the integration of voice support by systemic banks, ESAMA notes that universal implementation of the relevant arrangements is needed in all ATMs, regardless of bank or geographical area, and for the full range of transactions.

In physical bank branches, however, practices are recorded that, according to ESAMA, directly violate the dignity and autonomy of persons with visual disabilities. A typical example is the requirement of the presence of two witnesses, often with a notarial deed, for conducting transactions or signing documents. This practice violates banking and personal privacy, forcing individuals to disclose sensitive financial data to third parties, while, as noted, the validity of transactions could be ensured by employees of the bank itself.

Indicative of this is a recent incident that was reported to the ESAMA: a visually impaired person, who had forgotten his bank card at an ATM and it had been delivered to the branch, was asked to come forward with two witnesses to collect it, even though he had already confirmed his identity.

At the same time, non-acceptance of the signature with a stamp was recorded, despite it being a legal and established way of signing for people with visual disabilities, the lack of voice cash registers, and the mandatory establishment of appointments, even for simple transactions, unlike other public services, where priority status applies.

Special mention is also made of the restriction on cash withdrawal from physical cash registers. People with visual disabilities who do not have a card – due to unfamiliarity with ATMs and digital systems – cannot withdraw amounts of less than 400 euros, effectively limiting their access to their own money.

Proposals for people with visual impairments

Among other things, the ESAMA is calling for a binding directive to all credit institutions to ensure that people with a visual impairment of 67% or more are exceptionally served by physical banks throughout working hours. At the same time, it is proposed to review the circulars on the use of witnesses, to staff each branch with an authorised support employee, and to immediately adopt uniform accessibility standards for all banking applications and procedures.

Deaf and hard-of-hearing citizens: Invisible in the banking system

Similar serious problems are also recorded for deaf and hard-of-hearing citizens. As noted, banking institutions do not have an official, organized platform for remote interpretation in Greek Sign Language, while in several cases they even refuse to use existing relay services, citing privacy issues, without offering an alternative accessible solution.

At the same time, incidents of questioning the status and role of certified ENGL interpreters are recorded, despite the existence of official registers and recognised bodies such as the Association of Greek Sign Language Interpreters, the Federation of Deaf People in Greece, and the National Foundation for the Deaf.

Communication with banks is still, to a large extent, based on telephone service, in practice excluding deaf and hard-of-hearing customers. Call centres operate exclusively by voice communication, and there are no written channels, relay services or connection with sign language interpretation. At the same time, digital banking services often rely on telephone confirmations, voice alerts, or audiovisual material without subtitles and adequate written instructions.

Particularly worrying are cases where a witness is requested to be present to carry out transactions because the deaf or hard-of-hearing customer cannot act independently. The NESAMA refers to offensive and stigmatising practices that directly challenge the legal capacity of these citizens and violate fundamental rights.

The demands for substantive equality

Among the proposals of ESAMEA are the creation of a single central platform for remote interpreting in cooperation with the Hellenic Banking Association, the institutionalization of secure procedures compatible with GDPR, the mandatory acceptance of certified interpreters, and the establishment of an integrated framework for accessible communication with written channels, appointment facilities, and fully accessible digital services.

Particular emphasis is also placed on the need for mandatory training of bank staff on disability, accessibility, and communication issues, in cooperation with ESAMEA and the Federation of the Deaf of Greece.

“Inclusive” practically or formally?

Concluding its letter, ESAMEA declares that it remains at the disposal of the Hellenic Bankers Association for dialogue and cooperation, to shape a banking system that is truly accessible and inclusive for thousands of citizens with disabilities.

The letter

SUBJECT: “It is deemed necessary to ensure accessibility to banking services for people with disabilities.”

Mr. Speaker,

The National Confederation of Persons with Disabilities (NCDD) is the tertiary social and trade union organization of persons with disabilities and their families in the country, officially recognized as a Social Partner of the Greek State on disability issues.

Its main mission is to combat discrimination against persons with disabilities, chronic illnesses, and their families and to promote, protect and enjoy their human and constitutionally guaranteed rights. Regarding the human rights of persons with disabilities, these are enshrined in the United Nations Convention on the Rights of Persons with Disabilities, which our country, together with its Optional Protocol, ratified by Law 4074/2012.

With this letter, we convey to you our members’ complaints regarding the difficulties they face when using banking services and transactions, both digitally and at physical branches and automatic teller machines (ATMs).

Despite isolated improvements observed in some cases, the overall picture still creates conditions of exclusion, dependence on third parties, and violation of the autonomy, dignity, and personal data of persons with disabilities and requires an immediate and uniform response.

We provide you with a summary of problems and corresponding proposals regarding access to banking services and transactions, especially for people with visual disabilities and deaf and hard-of-hearing citizens:

Α. PERSONS WITH VISUAL DISABILITY.

1. Mobile Banking Apps (Mobile Banking Apps)

There are reports that mobile banking apps have serious accessibility deficiencies, making their use problematic for people with visual impairments.

In particular, they are not fully compatible with screen-reading software (e.g., VoiceOver, TalkBack) in basic functions such as payments, transfers, balance checking, card activation/management, etc., lack a clear and stable navigation structure, and do not allow basic transactions to be completed without the assistance of a third party. In addition, adequate alternative means of support when using the application is not accessible are lacking.

2. Automatic Teller Machines (ATMs)

The progress made by the systemic banks in integrating voice support into ATMs, in compliance with the European Accessibility Act (Law 4994/2022), is acknowledged. However, the universal implementation of the relevant regulations is deemed necessary so that all ATMs, regardless of the bank or geographical area, are fully accessible to people with visual disabilities and support the full range of transactions.

3. Physical bank branches

Physical branches continue to engage in practices that directly infringe on the autonomy and dignity of persons with visual disabilities, including:

– Mandatory presence of two witnesses, determined by a notarial deed, to conduct transactions or sign documents. This practice violates banking and personal privacy and forces traders to disclose sensitive financial data to third parties. It is also not justified when the validity of the transaction can be verified by the involvement of two employees of the same bank. Indicative of the problematic practice mentioned above is a recent incident reported to us by a visually impaired person who tried to retrieve the bank card that he had forgotten in an ATM when it was found and handed over to the bank. When he went to collect it, despite confirming his identity, he was urgently requested to have two witnesses present, or the card would not be returned.

– Not accepting a signature with a stamp, even though it is an established and legal way of signing for people with visual impairments.

– Lack of voice-operated cash registers, both in and out of stores.

– Mandatory establishment of appointments for all transactions, including simple procedures, unlike other public services, where priority status is provided for persons with disabilities.

4. Restriction on the use of cash

Persons with visual disabilities, who do not have a debit or credit card due to unfamiliarity with electronic banking systems (such as ATMs and other digital services), face significant restrictions in accessing their cash because they are not allowed to withdraw amounts of less than 400 euros from physical cash registers.

Based on the above, it is proposed to implement the following measures to improve the service for people with visual disabilities:

– Issue a clear and binding directive to all credit institutions – members of the Union of Banks, according to which persons with a visual impairment of 67% or more, upon presentation of a decision of the KEPA, a certificate of a competent health committee or a disability card, are exceptionally served by the natural funds, within their opening hours and throughout their duration.

– Review and amendment of the current circulars regarding the use of witnesses in banking transactions, to ensure the protection of the personal data and dignity of persons with visual disabilities.

– Provision for staffing each bank branch with an authorized employee responsible for providing support to persons with visual disabilities who have difficulties in using digital banking systems, regardless of whether they have a bank card.

– Immediate adoption of uniform accessibility standards for all mobile banking applications of the Member States of the Union, as well as for physical banking procedures, to ensure their full functionality and accessibility for people with visual disabilities, in accordance with the provisions of the European Accessibility Act (Law 4994/2022).

Β. Deaf and disabled citizens

1. Lack of a remote interpreting platform in Greek Sign Language

Banking institutions do not have an official and organised video relay service platform for the service of deaf and hard-of-hearing customers.

2. Refusal to accept remote interpreting on the grounds of personal data

In several cases, banking institutions refuse the use of remote interpreting (e.g., the Greek Sign Language and Hand Reading Relay Service of the National Foundation for the Deaf), citing privacy issues, without offering an alternative, accessible solution.

3. Questioning the status and role of Greek Sign Language interpreters

Some banking establishments refuse to accept the presence of ENGL interpreters, questioning their status, despite the existence of official registers and recognised bodies, such as:

– the Association of Greek Sign Language Interpreters,

– the Federation of the Deaf of Greece,

– the National Foundation for the Deaf.

4. Inappropriate and inaccessible means of communication – Digital and telephone banking services

Many banking institutions still rely almost exclusively on telephone communication and customer service, which makes it virtually impossible to serve deaf and hard-of-hearing citizens. At the same time, alternative, equal, and accessible communication channels are absent.

In addition, digital banking services (websites, applications, and e-banking systems) are often not designed with accessibility in mind, as:

– rely on telephone confirmation or voice alerts,

– include audiovisual material without subtitles,

– do not provide clear and adequate written instructions for critical procedures (such as identification, security, and transaction confirmation).

A particular problem is also found in the operation of call centers, which operate exclusively through voice communication, with no provision for written service, relay services, or the possibility of connecting to remote interpretation at the N.N.G.

5. Requirement of the presence of a witness – Questioning the autonomy and legal capacity of deaf and hard-of-hearing citizens

Incidents have been recorded in which banking establishments require the presence of a witness when conducting transactions, because the deaf hard of hearing customer cannot act autonomously. This practice is completely unjustified, offensive, and stigmatising, as it directly challenges the autonomy and legal capacity of deaf and hard-of-hearing citizens and constitutes a violation of fundamental rights.

6. Lack of training of bank staff

Bank staff, in most cases, lack basic training in accessibility and communication with deaf and hard-of-hearing customers, which leads to misunderstandings, delays or even denial of service.

Based on the above, we recommend implementing the following measures to improve service to deaf and hard-of-hearing citizens:

– Creation of a single, centralized platform for remote interpreting by banking institutions, in cooperation with the Hellenic Banking Association, with the participation of certified Greek Sign Language interpreters.

– Establishment of secure remote interpretation procedures, fully compatible with the General Data Protection Regulation (GDPR), to ensure unhindered access of deaf and hard-of-hearing citizens to basic banking services.

– Mandatory acceptance of certified interpreters by the H.N.G. and recognition of a single register of interpreters by the Hellenic Banking Association.

– Establishment of a comprehensive and uniform framework for accessible communication and services for deaf and hard-of-hearing citizens, including:

– written communication channels (email, SMS, chat),

– possibility of scheduling appointments,

– access to an official remote interpreting platform at the CNG, for immediate or scheduled service,

– connection of call centres to written and remote interpretation services,

– ensuring accessibility of digital banking services in accordance with international standards, with special provisions for deaf and hard-of-hearing users.

– Issue an explicit and binding directive to all banking institutions that deaf and hard-of-hearing citizens are fully autonomous persons, with full legal capacity, and that their communication and service can be carried out on an equal basis:

– with the assistance of a certified Greek Sign Language interpreter,

– through written communication,

– or by lip-reading, if this is the client’s choice.

– Mandatory training of bank staff on disability, accessibility, and communication issues, in cooperation with the H.S.A.M.A. and the Federation of the Deaf of Greece.

We remain at your disposal for dialogue and cooperation, with the aim of shaping a truly accessible and inclusive banking system.

In anticipation of your response and of our information in this regard, we thank you warmly in advance.