For regulated organisations, accessibility is part of whether a journey works in practice. It shapes how clearly customers can move through each step, complete key tasks, and get the support they need.
When disabled customers cannot read, navigate, verify, recover, or get help in the way that works for them, the service creates unnecessary barriers and falls short of basic usability.
On Regulated Digital, Diane Lightfoot, CEO of Business Disability Forum, explains why disabled customers still face avoidable barriers in communications, service design, and customer support, and what firms in regulated sectors can do differently.
Build for choice, clarity, and real-world use from the start, and you reduce friction for disabled customers, lower retrofit costs, and create journeys that work better for everyone.
Created from episode transcript
The Scale of the Issue
Disabled Customers Are Not an Edge Case
Disabled people are not a niche audience sitting outside the “main” customer base.
The Family Resources Survey puts disabled people at one in four of the UK population, under a broad Equality Act definition.
Service teams often design around a narrow picture of disability, then miss the wider range of needs that appear in real journeys, from mobility and sight to memory, fatigue, speech, hearing, and neurodiversity.
Accessibility Is Often Still Treated as an Afterthought
The Women and Equalities Committee found that many businesses still do not consider disabled consumers’ needs from the outset, and where accessibility is addressed, it is often treated as an afterthought rather than a design principle.
The issue is rarely a weak final checklist alone. More often, firms treat inclusion as something separate from the product or service itself.
Choice Is a Service Design Decision
More Channels Mean Less Exclusion
The practical starting point is simple: offer choice.
Choice is not an extra channel. It is how firms avoid building exclusion into the default route.
A phone-only model excludes some people. A digital-only model excludes others. A process that assumes every customer can hear clearly, see clearly, speak clearly, remember multiple codes, use biometrics, and complete every step in one sitting will break for more people than many teams realise.
This applies to sensitive communications too. A secure route still needs to be workable. If someone cannot complete the authentication step, read the format, or recover after a mistake, the journey has failed even if the control looked strong on paper.
BDF research into banking and insurance found that disabled consumers were looking for good customer service, accessible information, and the ability to communicate in ways that suited the customer rather than the provider.
What BDF Found On Access Needs
BDF research in banking and insurance found disabled consumers wanted accessible information, good service, and communication shaped around the customer rather than the provider.
That expectation bites hardest where firms ask customers to repeat the same access needs on every contact.
Preference Data Only Helps If It Is Used
It is not enough to offer different routes if customers have to explain their needs again every time they make contact.
What To Capture At Onboarding
How the customer wants to be contacted.
What support format works best for them.
Which channels should be avoided on future contact.
Regulated firms already collect important information at onboarding and during servicing. The question is whether they use those moments to ask how someone wants to be contacted, what support works best, and which channels should be avoided.
"Regulated firms often treat accessibility as a design issue and security as a control issue. In practice, the same journey has to work for someone who needs plain language, flexible authentication, and a support route that does not reset every time they call back."
Paul Holland, Founder and CEO, Beyond Encryption (Mailock)
The same gap often shows up in day-to-day delivery, where preference data exists on paper but does not reach the team handling the next contact.
"When preference data exists but frontline teams cannot see it, the firm keeps asking the same customer to repeat the same access needs. Accessible delivery is as much an operational handoff problem as a website checklist."
Those operational gaps sit alongside the design and testing work firms still need to get right.
Build Accessibility Into the Journey
Start With Lived Experience
Government guidance on inclusive services and accessible services is clear that teams should think about exclusion before they build, bring a wide range of users into research, and test throughout design and delivery.
What GOV.UK Expects On Inclusion
Teams should design for exclusion before build, involve a wide range of users in research, and keep testing through delivery.
That only works in practice when firms bring in people with lived experience early, understand where the friction sits, and make sure product, technology, procurement, security, and inclusion teams are not working in separate lanes.
WCAG Matters, but It Is Not the Whole Story
The standard reference point for digital accessibility remains WCAG 2.2, and organisations in regulated sectors should take it seriously.
But WCAG itself makes clear that it does not address every type, degree, or combination of need in full. A journey can pass a checklist and still be tiring, confusing, or fragile in real use.
Where WCAG Stops Short
Passing a WCAG checklist does not guarantee a journey that is workable under memory load, confusion, or recovery after mistakes.
GOV.UK’s guidance on accessibility testing covers that gap. Teams need both automated and manual testing, because relying on one alone will miss real problems in code, content, and interaction design.
The Details That Decide Whether a Journey Works
Accessible Information Has to Be Specific
Accessibility often fails at the level of detail, not in a headline policy statement.
How big are the buttons? Does the device make a sound? Is the form compatible with assistive technology? Can someone pause and come back later? Does the support page explain what a control actually does? Is the product named in language customers will recognise?
Sending Important Documents At Scale?
Learn how Mailock Automated helps organisations protect high-volume customer communications without forcing every recipient through a portal.
User testing has shown how quickly that breaks down. Some customers with a learning disability struggled to find a credit card because the provider had chosen not to call it a credit card. Plain language is often part of the product itself, not an optional layer around it.
Cognitive Accessibility Still Gets Less Attention Than It Needs
Many organisations are getting better at visual accessibility, screen reader compatibility, and dexterity-related issues, but still miss the demands placed on memory, concentration, language processing, and decision-making.
W3C’s COGA guidance is useful here because it highlights memory load, unclear labels, multi-step tasks, complex authentication, and poor recovery paths after mistakes.
In regulated journeys, customers are often comparing options, sharing sensitive data, or completing tasks they do not perform very often.
Four Questions For Cognitive Load
Ask what the customer has to remember. Codes, passwords, and time-limited steps all add load.
Ask what the customer has to decode. Labels, product names, icons, and error messages should be plain and direct.
Ask what happens after a mistake. Good journeys let people recover without panic or penalty.
Ask what happens when the default route does not work. Choice is the fallback.
Those checks matter most where customers compare options, share sensitive data, or complete tasks they rarely perform.
Trust Comes From Honesty and Human Support
Be Clear About Limits, and Equip Staff to Help
Disabled customers would often rather know a limitation upfront than discover it after they have committed time, effort, or travel.
That affects trust as well as accessibility. Clear information about what is and is not available helps people choose the right route and prepare for what they need.
Accessible journeys also do not end with the interface. Staff do not need perfect knowledge of every condition. They need the confidence to start a respectful conversation, avoid assumptions, and solve problems.
"How can I help you, how can I help make this the best possible experience for you?"
That kind of support only scales when leadership, accountability, and resourcing match the intent stated in accessibility policies.
Leadership Turns Intent Into Delivery
Inclusion Needs Accountability
The strongest organisations make accessibility visible in leadership, accountability, and resourcing, as well as in statements of intent.
That is consistent with regulatory expectations. The FCA’s vulnerable customer guidance says firms should understand customer needs, equip staff to respond, and reflect those needs in product design, communications, and support.
What The FCA Expects On Vulnerable Customers
Firms should understand customer needs, equip staff to respond, and reflect those needs in product design, communications, and support.
In practice, accessibility should not sit in a narrow compliance box. It belongs in service design, customer outcomes, operational risk, and governance.
Accessible by Design Is Better Service Design
For regulated firms, accessible by design belongs with good service, fair treatment, and sound operational design.
Accessible by design is better service design, not a separate inclusion project.
When firms build for different communication needs, make room for clear support, and test journeys in real conditions, they reduce avoidable friction for disabled customers and improve the experience for other customers too.
FAQs
What Does “Accessible by Design” Mean in Practice?
It means considering disabled customers at the start of research, content, design, procurement, and testing, rather than waiting for an audit at the end.
Is WCAG Compliance Enough on Its Own?
No. WCAG is essential, but real journeys also need plain language, workable support, flexible authentication, and testing with people who have different access needs.
Why Is Choice So Important in Regulated Journeys?
Because no single channel, format, or authentication model works for everyone. Choice reduces exclusion when a customer cannot use the default route.
What Is a Practical First Step for Smaller Teams?
Review your highest-friction customer journey and identify where people are forced into one channel, one format, or one authentication method. That usually reveals the first barrier worth fixing.
Sam Kendall works on digital marketing at Beyond Encryption, helping build B2B marketing activity around research, first principles, and sustainable growth. He writes about marketing effectiveness, positioning, customer communications, and digital culture, with longer-form work published at ATNL.
Sam Kendall
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