You have been asked to feed into a Consumer Duty gap analysis, and someone has asked: what about accessibility? Consumer Duty accessibility is easy to get wrong in both directions, so this guide sets out what a regulator-facing gap analysis needs.
The short answer first. The Consumer Duty, the FCA's (Financial Conduct Authority's) rules on good outcomes for retail customers, does not name WCAG (the Web Content Accessibility Guidelines) or any other digital standard. What it does ask is that you can show disabled customers get outcomes as good as everyone else's, and that you keep the evidence.
This guide covers what the Duty says, where the Equality Act sits, and the evidence a gap analysis needs. It is written for digital, product and compliance leads at FCA-regulated firms.
Does the Consumer Duty Require WCAG?
No. In the rules and guidance we reviewed, nothing requires WCAG or any digital accessibility standard.
What the Duty sets is four outcomes: products and services, price and value, consumer understanding, and consumer support. Accessibility sits mostly in the last two.
On consumer understanding, the rules in PRIN 2A(opens in new tab) (the Consumer Duty section of the FCA Handbook) say communications must meet customers' information needs and be likely to be understood. Firms must tailor them to customer characteristics, including characteristics of vulnerability, and to the channel, whatever channel is used. The FCA's Consumer Duty guidance, FG22/5(opens in new tab), adds: "Digital communications should be compatible with different mediums, for example computers, tablets or smartphones."
On consumer support, FG22/5 lists harms that include "phone systems, menus or webchats that are difficult to navigate" and "badly designed websites that make it difficult for customers to find key information online". The FCA does not tell firms which channels to offer, and digital-only is acceptable. But for a firm with one channel, "Unclear or confusing digital (or other) customer journeys will not meet this standard", and firms "must therefore ensure that the support they offer allows for reasonable adjustments to be made".
There is one place WCAG does appear. The FCA's consumer support outcome good practice page(opens in new tab), published in March 2025, notes that many firms improved accessible communications for customers with impairments, including WCAG-compliant websites and documents in large print, audio or braille. That describes what some firms chose to do. It is good practice observed, not a rule.
Vulnerable Customers and the Equality Act
The FCA's vulnerable customers guidance, FG21/1(opens in new tab), is guidance, not rules, and it says it does not provide a checklist. It applies to firms that offer self-service digital channels. It names "physical disability", "hearing or visual impairment" and "low mental capacity or cognitive disability" as health drivers of vulnerability, and "poor or non-existent digital skills" as a capability driver. It also says "sight and hearing impairments can make some channels of communication impossible to use and makes alternative accessible formats essential." Its examples of how firms can put this into practice include accessible websites, alongside BSL (British Sign Language) video services, large print and audio. They are examples, not requirements, and no standard is named.
The Equality Act 2010 is the legal duty underneath. Service providers must make reasonable adjustments for disabled people, and because the duty is owed to disabled people generally, firms have to anticipate needs rather than wait to be asked. The Act does not name WCAG either. The FCA cannot enforce the Equality Act; the EHRC (Equality and Human Rights Commission) does. But the FCA says a breach of the Equality Act is likely to be a breach of its own rules, including its Principles. Our overview of the UK financial services layer covers the wider picture.
What a Consumer Duty Gap Analysis Needs to Show on Accessibility
A gap analysis compares what the Duty expects you to be able to show with what you can show today. Accessibility evidence fits the Duty in five places.
1. Outcomes by customer group
A key question FG22/5 gives boards is: "Are certain groups of consumers getting different outcomes, and if so why?" The monitoring rules in PRIN 2A ask firms to check that customers get the right information and support, identify differences in outcomes between groups, find root causes and act. FG22/5 says firms "should produce and regularly review MI on the outcomes they are delivering for customers with characteristics of vulnerability" (MI meaning management information). Where customers who share a protected characteristic under the Equality Act get worse outcomes, firms should have processes to investigate. The Duty does not replace the firm's Equality Act obligations.
The evidence question: can you show that customers using assistive technology complete your key journeys (apply, pay, get help, complain, switch) as well as other customers do?
2. Testing of your website, app and communications
Among the data sources FG22/5 lists for monitoring are "consumer testing of user interfaces and design such as websites and apps" and "auditing customer journeys". That paragraph does not use the word accessibility, so do not present it as an accessibility rule. It does describe the kind of evidence an accessibility test produces. FG22/5 also says: "An audit of customer journeys could identify differences in experience or frictions that affect certain groups of customers but not others." And it says testing should not reflect only the views of the legal or compliance staff who wrote the communication.
Here is a gap worth checking. Usability testing with a general customer panel tells you whether journeys work for most customers. It does not tell you whether they work for someone using a screen reader, switch control or magnification. That is the group the "worse outcomes for some groups" question is about. Our guide to accessibility testing with assistive technology explains how that testing works.
3. Communications in a format people can use
FG22/5 is direct: "Firms also have a legal duty under the Equality Act 2010 to anticipate the needs of disabled customers and provide reasonable adjustments to enable them to use the service. This can include providing information in an accessible format."
It gives an example. A customer who could not read large print or braille asked their bank to send letters by email so software could read them aloud. The bank kept sending paper, and the FCA said the firm "did not act reasonably to avoid consumer harm". The good practice it describes is a firm that "signposts a clear way for customers with a hearing or visual impairment to request communications in a format that meets their needs".
The evidence: a clear, easy-to-find route to request another format, and a record that requests are met.
4. Support without unreasonable barriers
FG22/5 calls friction that deters customers from acting in their interests, "such as making a complaint or switching product", sludge, and says it "is not consistent with the Duty". Firms must be able to "justify and evidence" any extra steps.
The evidence: complaint, cancellation and switching journeys tested with assistive technology, and shown to be as clear as the sales journey.
5. Records the board and the FCA can see
The PRIN 2A rules require the board to review and approve a report on the outcomes retail customers are getting at least once a year, confirm compliance, and agree actions on any risks. The first was due by 31 July 2024. Firms do not have to send it to the FCA, but they must be able to produce it.
This assessment will be part of the evidence we use to assess a firm's compliance with the Duty. We expect to be provided on request with the report and the management information (MI) that sits behind it.
FG22/5 adds: "Firms will need to be able to provide evidence of their monitoring and assessment of these outcomes and any resulting action, on request." It also says "There is no prescribed format for the way in which firms evidence their monitoring", but records must show the issues found and actions taken. Firms "should develop MI that goes beyond complaints data", for example "file reviews, sludge audits and focus groups".
The evidence: dated findings, the actions agreed, and when each was fixed.
Where an Accessibility Audit Fits
This part is our view, not FCA text.
A manual audit of your website and app against WCAG 2.2 AA, done by someone using assistive technology, is one practical way to produce the user interface testing and journey audit evidence FG22/5 describes. It also gives the board a dated record of what was found and what was fixed. In our view it is one of the clearest ways to show the outcome for disabled customers.
The Duty does not require one, and an audit is not the only evidence. It sits alongside complaints, support data and customer feedback, and it is strongest when the findings feed the same MI the board already sees.
One caution. A one-off audit goes stale with every release, so the record matters more than the report. What the FCA says it expects on request is evidence of your monitoring and the action you took, not a single PDF.
If your services are also sold into the EU, they may fall under the European Accessibility Act (EAA) and EN 301 549, the EU's harmonised accessibility standard. We cover that in does the EAA apply to UK businesses.
If Your Digital Journeys Run on a Supplier's Platform
Outsourcing the platform does not outsource the Duty. Under FG22/5 the firm stays accountable and needs arrangements with its outsourcers to get the data it uses to monitor outcomes. Where a firm uses another regulated firm to carry out a regulated activity for it, both must monitor outcomes. A practical first step is to ask each supplier for their conformance report. Our guide to the accessibility question in enterprise deals sets out what a supplier should be able to send you.
What the FCA Has Done So Far
In the sources we reviewed, the FCA has not published an enforcement action or review naming a firm for digital accessibility failures. Its Enforcement Watch(opens in new tab) of 7 July 2026 reported 11 open Consumer Duty investigations, none reported as concerning accessibility, and we found no Consumer Duty fine.
The absence of a case is not the absence of an expectation. The board report and the MI behind it are what the FCA says it will ask for. The firm that can show good outcomes for disabled customers, with records to back it, is the one with nothing to explain.
Where AUDITSU Fits
Your evidence belongs to you. AUDITSU helps you produce it and keep it current.
AUDITSU walks your team through an audit of your website or app, screen by screen, and keeps the findings as a living record rather than a one-off PDF. When a gap analysis or board report asks for accessibility evidence, you answer from the same record. If you want an independent tester to check your journeys, a manual audit against WCAG 2.1 AA is available too.
If you have been asked to feed into a gap analysis and want to talk through what your evidence should look like, book a call.