Accessible by Design: Making Regulated Customer Journeys Work for Disabled People

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.

In this episode of 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.

The central takeaway is simple: build for choice, clarity, and real-world use from the start, and you reduce friction for disabled customers, lower the cost of retrofitting, and create journeys that work better for everyone.

The Scale of the Issue

Disabled Customers Are Not an Edge Case

One of Diane’s clearest points is that disabled people are not a niche audience sitting outside the “main” customer base.

Recent UK figures from the Family Resources Survey show that one in four people are disabled, and the legal definition under the Equality Act definition is broad.

That matters because 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.

That lines up with the episode. The issue is not a weak final checklist. It is treating inclusion as something separate from the product or service itself.

Choice Is a Service Design Decision

More Channels Means Less Exclusion

If there is one phrase that runs through the conversation, it is this: offer choice.

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.

Preference Data Only Helps If It Is Used

Diane also highlights a common frustration: it is not enough to offer different routes if customers have to repeat their needs every time they make contact.

Regulated firms are often well placed to do better because they 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.

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.

The discussion makes the same point in more practical language. 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.

That is why GOV.UK’s guidance on accessibility testing is so important. 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

A strong theme in the episode is that accessibility often fails at the level of detail.

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?

Diane gives a memorable example from user testing: 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 not an optional simplification around the product. In many cases, it is part of the product.

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.

That matters in regulated journeys, where customers are often comparing options, sharing sensitive data, or completing tasks they do not perform very often.

• 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.

Trust Comes From Honesty and Human Support

Be Clear About Limits, and Equip Staff to Help

One of Diane’s clearest points is that disabled customers would often rather know a limitation upfront than discover it after they have committed time, effort, or travel.

That is a trust issue as much as an accessibility issue. 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?"

Diane Lightfoot, CEO, Business Disability Forum

Leadership Turns Intent Into Delivery

Inclusion Needs Accountability

Diane argues that the best organisations make accessibility visible in leadership, accountability, and resourcing, not just 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.

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 is not separate from good service, fair treatment, or sound operational design. It is part of all three.

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 create better experiences for everyone else as well.

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.

References

Family Resources Survey: Financial Year 2024 to 2025, GOV.UK, 2026

Definition of Disability under the Equality Act 2010, GOV.UK, 2010

Accessibility of Products and Services to Disabled People, Women and Equalities Committee, 2024

Banking and Insurance - What Disabled Consumers Choose to Buy and Why, Business Disability Forum, 2023

Making Your Service More Inclusive, GOV.UK Service Manual, 2025

Making Your Service Accessible: An Introduction, GOV.UK Service Manual, 2016

Testing for Accessibility, GOV.UK Service Manual, 2019

Web Content Accessibility Guidelines (WCAG) 2.2, W3C, 2024

Making Content Usable for People with Cognitive and Learning Disabilities, W3C, 2021

Guidance for Firms on the Fair Treatment of Vulnerable Customers, Financial Conduct Authority, 2021

Reviewed by

Sam Kendall, 15.04.2026