NBU Requirements for the Inclusiveness of Financial Institutions

NBU Requirements for the Inclusiveness of Financial Institutions

Inclusion in the financial sector is not only a matter of social responsibility but also a regulatory requirement. The National Bank of Ukraine (NBU) actively implements a financial inclusion policy aimed at ensuring equal access for all citizens to financial services, including people with limited mobility, persons with disabilities, the elderly, and others.

Below we will consider the main NBU inclusiveness requirements that banks and other financial institutions must comply with.

Legislative and Regulatory Framework

The regulation of inclusiveness requirements is based on the following acts:

• Law of Ukraine “On Financial Services and State Regulation of Financial Services Markets”

• Law of Ukraine “On the Fundamentals of Social Protection of Persons with Disabilities in Ukraine”

• NBU Resolution No. 64 dated 28.05.2021 “On Approval of the Regulation on Inclusiveness Requirements for Banking and Other Financial Services”

• State Building Standards (DBN B.2.2-40:2018 “Inclusiveness of Buildings and Structures”)

Key NBU Requirements for Financial Institutions

1. Architectural Accessibility of Premises

Financial institutions are required to ensure:

• availability of ramps, elevators, and lifts;

• door openings wide enough for wheelchair access;

• barrier-free access to cash desks, self-service terminals, and ATMs;

• sanitary facilities accessible to persons with disabilities;

• tactile indicators and contrast markings for people with visual impairments.

2. Accessibility of Digital Financial Services

Banks and non-banking financial institutions must ensure:

• accessible websites and mobile applications for people with visual impairments;

• the ability to use screen readers;

• convenient navigation, enlarged fonts, and high-contrast colors.

This complies with the principles of WCAG 2.1 (Web Content Accessibility Guidelines), which every financial institution must follow.

3. Customer Service with Special Needs Consideration

• Staff must be trained in proper communication with persons with disabilities.

• Provision of sign language interpretation services or remote access to an interpreter.

• Availability of printed materials in Braille or electronic format.

4. Monitoring and Reporting

The NBU obliges financial institutions to:

• conduct regular monitoring of compliance with inclusiveness requirements;

• submit reports on the state of accessibility implementation;

• respond to citizen complaints regarding violations of inclusive access rights.

Common Violations and Mistakes of Institutions

1. Installation of ramps with excessive slopes (not compliant with DBN).

2. Lack of audio support in ATMs.

3. Mobile applications inaccessible for people with visual impairments.

4. Ignoring client needs during renovations or opening new branches.

Recommendations for Financial Institutions

• Conduct an infrastructure audit to assess compliance with inclusiveness standards.

• Engage specialists in barrier-free environment design.

• Organize staff training on serving persons with disabilities.

• Consider DBN B.2.2-40:2018 requirements in new construction or office/branch renovations.

Contact GlobalBud Ukraine

If you are a representative of a financial institution planning reconstruction, new construction, or compliance checks with inclusiveness requirements — contact GlobalBud Ukraine.

Our team of experienced engineers, architects, and lawyers will provide:

• premises inclusiveness audits;

• development of technical solutions in accordance with DBN;

• legal support to comply with NBU requirements;

• a full range of turnkey services for banks and non-banking institutions.

We work with both Ukrainian companies and international financial institutions.