The Australian Banking Association (ABA), the industry group representing the country’s largest banks, has released its new guiding principles on accessible design for banking services. 

The principles aim to ensure accessible banking for the four million Australians living with disability by providing accessibility design principles for banking services like mobile, ATMs, eftpos machines and web sites. 

The banking industry has faced criticism in the past over poorly designed digital technology, including point of sale terminals that fail to provide adequate access for people with a vision impairment.

While the new principles are a welcome update, some advocates say the new guidelines are a “watering down” of the 16-year-old standards they replace. 

The new principles are voluntary, lack technology specifications and do not carry the force of law. The ABA says the new principles are no less enforceable than the previous standards and following the new guidelines “will carry some weight as a defence against a complaint lodged under the Disability Discrimination Act”. The industry group also says the lack of prescription is a deliberate decision to promote flexibility.

Gisele Messnage, founder and coordinator of the Digital Gap Initiative, an advocacy organisation for inclusive digital accessibility, said the new principles are less enforceable and prescriptive than the already loose 2002 standards.

“The 2002 standards were not prescriptive or legally enforceable but they included technical specifications, as is generally the role of standards,” Messnage told Which-50.

“The new ‘principles’ are not prescriptive; have no legal force and also, in the view of the Digital Gap Initiative (DGI) lack technical specifications.”

The DGI is not opposed to the idea of guiding principles and acknowledges overly prescriptive standards can be limiting. But, Messnage says, an absence of standards can produce accessibility solutions that lack uniformity and ultimately shift the burden back on to people with disabilities.

The challenge is evident in payment systems requiring a PIN verification, Message said.

“In the absence of an enforceable standard, we are currently experiencing in Australia an influx of ‘pin on glass’ payment systems. So even if the Albert, BladePay and Square were all to implement the ABA’s guiding principles, this may not lead to any uniformity in the way that for example accessibility support is provided.”

Commonwealth Bank’s point of sale Albert terminal is the subject of a legal battle over its accessibility options. Source: MediaAccess.org.au

The ABA told Which-50 the switch to principles and a lack of technical standards is a deliberate decision to allow greater flexibility as technology advances.

“The rapid pace of technological change has meant that the previous standards, which prescribed not only ‘what’ was to made accessible but ‘how’, were out of date and not fit for purpose,” an ABA spokesperson said.

“The principles, based on international best practice including the seven principles of universal design, guide each organisation to ensure new technology, even as it rapidly changes, is accessible to the community.”

Overdue update

Former Disability Discrimination Commissioner Graeme Innes led a review of the 2002 standards before developing the new principles this year after consulting with the disability sector and the banking industry. 

Innes told Which-50 the less prescriptive principles were an “absolutely intentional” decision and they are no less enforceable than the 2002 standards.

“The standards became very out of date to the extent that they were almost irrelevant because of the significant technology change. So the decision was made to have higher-level strategic coverage which will provide greater flexibility with the technology and that’s what the principles do.”

Banks will need to commit to the voluntary principles and the ABA is developing an assessment tool so banks can report their progress.

Former Disability Discrimination Commissioner Graeme Innes.
Source: graemeinnes.com

“I think it’s really important for the banking industry to make these commitments and it’s important for the industry to follow them through,” Innes said.

“These principles are based on universal design concepts, which means products are designed with everyone in mind rather than just for people without disabilities, and there’s the flexibility built in there to allow them to change with the times.”

Overzealous standards have been seen as a barrier to technology innovation but, according to Messnage, that argument is often applied selectively to the detriment of the disability sector.

“There is an influential argument that prescriptive, mandatory standards can hinder innovation and competition, especially in the fast moving world of digital technology,” she said.

“However, it is an argument that appears to be applied selectively: it does not appear for example to apply to security, privacy, safety  or such other mainstream concerns.”

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