Beginning October 1, 2026, Australia’s financial sector operates under a fresh regulatory framework. Created by the Australian Finance Industry Association (AFIA), the Finance Industry Code of Practice stands as the nation’s inaugural set of rules tailored specifically to non-bank lenders and specialized financial institutions, bringing digital accessibility directly into focus.
While institutions might easily overlook this digital mandate amid broader priorities like fair treatment, transparency, and consumer safeguards, its inclusion is vital. It shifts accessibility out of the IT department and places it firmly within consumer relations, grouping it alongside plain-language requirements, assistance for vulnerable clients, and transparent multi-channel communication.
This overview outlines the Code’s purpose, scope, specific accessibility mandates, and practical interpretations of “reasonable steps” for non-bank lenders.
What is the AFIA Finance Industry Code of Practice?
Released in September 2025 and currently in Version 2.0 (dated December 2025), the Code becomes fully active on October 1, 2026, following a transition period designed to help members adjust their operations. It establishes benchmarks for fairness, transparency, and integrity throughout the non-bank and specialist lending market.
This goes beyond mere marketing. The Finance Industry Code Compliance Committee independently audits the Code, holding the power to probe suspected violations, mandate remedial actions, and penalize non-compliant members. This independent oversight gives the guidelines their real authority.
Who does the AFIA Code apply to?
The rules extend widely across AFIA participants offering consumer and small-business credit, financing, and novated leases in Australia, encompassing:
- Personal loans, credit cards, revolving credit, and consumer finance
- Home and investment property mortgages
- Equipment, asset, and vehicle financing
- Fleet management finance
- Small-business credit products
- Novated lease arrangements
Certain boundaries apply. Government, semi-government, major corporate, and commercial real estate products are excluded, as are AFIA members already bound by equivalent rules like the Customer Owned Banking Code of Practice or the Banking Code of Practice.
Additionally, AFIA maintains separate rules for online small-business lending, Buy Now Pay Later services, and insurance premium funding. Organizations governed by those specialized frameworks answer to them rather than this general Code.
Ultimately, this targets non-bank lenders, vehicle and asset finance companies, fintech credit providers, novated leasing businesses, and specialist financiers.
What the AFIA Code says about digital accessibility
This section directly impacts anyone managing a finance provider’s digital presence.
The rules obligate participants to pursue reasonable measures ensuring that all applications, websites, and customer communication channels adhere to appropriate accessibility benchmarks, such as the Web Content Accessibility Guidelines (WCAG).
This phrasing is deliberate and careful. The Code does not mandate complete WCAG AA compliance for every financial website by the October deadline. Instead, it asks for good-faith, proportionate efforts aligned with relevant benchmarks, mentioning WCAG as an example rather than enforcing a rigid pass-or-fail standard.
Furthermore, this accessibility pledge does not exist in isolation; several complementary provisions reinforce it:
- When a provider learns that a client requires extra assistance due to a disability, sensory impairment, or language barrier, they must take reasonable steps to facilitate that interaction.
- Signatories promise to use straightforward language, cutting out unnecessary legalistic and technical jargon.
- Firms pledge to supply transparent, useful details helping consumers make educated choices continually throughout the product lifecycle.
- Digital platforms, including apps and websites, must prominently feature grievance procedures and financial hardship assistance options.
Altogether, these guidelines transform accessibility into a measure of consumer success rather than a mere technical checkbox.
Why accessibility matters so much in finance
Roughly one in six Australians lives with a disability, the majority of which are non-visible. Factor in the millions who speak languages other than English at home or struggle with dense financial text, and the scale of those impacted by inaccessible digital media becomes apparent.
Financial services complicate this further than most industries. Agreements are lengthy, terms are intricate, and choices carry severe monetary consequences. A user might navigate a technically compliant site yet still fail to grasp a loan contract, locate assistance, or complete a hardship application.
That is why the Code’s emphasis on vulnerability carries such weight. It formally acknowledges factors such as cognitive differences, aging-related challenges, literacy gaps, severe illness, financial distress, and domestic abuse. Customers facing these hurdles shouldn’t need advanced digital literacy just to understand their choices or seek help.
Viewed this way, accessibility transcends screen reader compatibility; it becomes about whether your audience can genuinely comprehend the information presented to them.
What “reasonable steps” looks like in practice
Fortunately, the Code’s terminology remains flexible. “Reasonable steps” represents an achievable benchmark that aligns with a core principle:
You cannot ignore the issue. You cannot fix everything at once. But you can take measured action and record your progress.
Standing still is indefensible under an independently monitored framework, while perfection is neither realistic nor mandatory. The middle ground involves steady, recorded advancement. For a financial institution, taking defensible steps typically involves:
- Assessing your current digital footprint against recognized benchmarks like WCAG 2.2 AA.
- Pinpointing existing barriers and determining which ones affect your customers most.
- Resolving those obstacles incrementally over time rather than attempting an impossible overhaul.
- Assisting struggling clients through alternative reading, audio, translation, and comprehension tools.
- Maintaining logs of your monitoring efforts, completed fixes, and underlying rationale.
- Releasing an honest accessibility statement detailing your current status and ongoing initiatives.
These final items are just as crucial as the repairs. Under independent oversight, proving the measures you took matters as much as taking them, a concept known as Documented Accessibility Progress: a transparent, continuous chronicle of your improvements and actions.
The risks of standing still
Accountability is a core feature of the new Code. Because compliance is independently audited, ignoring these commitments invites investigations, mandated corrections, and penalties from the Finance Industry Code Compliance Committee.
Beyond the Code, digital accessibility already carries legal weight domestically via the Disability Discrimination Act 1992, which has previously spawned legal actions against Australian entities.
Reputation is also on the line. Finance is built on trust; firms actively working to include and support all users bolster their standing, whereas negligence courts disaster at a time when consumers and watchdogs demand higher standards.
Rather than causing panic, this points to a clear takeaway: doing nothing is the hardest path to justify.
Financial accessibility extends far beyond technical compliance; it determines whether the individual behind the screen grasps the details impacting their financial health. The Code demands reasonable measures. Executing those measures, and proving you did, defines success.
Know where you stand: Accessibility Checker
The Recite Me Accessibility Checker audits websites against frameworks like WCAG 2.2 AA, highlights obstacles, helps prioritize repairs, and monitors evolution over time, replacing guesswork with concrete data regarding your compliance status.
Help more customers use and understand your content: Assistive Toolbar
The Recite Me Assistive Toolbar equips visitors with tools to alter text styling, listen to audio read-alouds, translate materials into diverse languages, and utilize reading aids. In a high-stakes, complex sector, this directly supports the Code’s emphasis on comprehension.
Make your documents accessible: PDF Remediation and PDF Intercept
The industry relies heavily on paperwork, including disclosures, agreements, statements, and hardship forms. Recite Me identifies and rectifies inaccessible PDFs at scale while offering readable alternatives, ensuring essential data remains accessible.
Evidence the steps you take: Accessibility Documentation
Demonstrating due diligence is as vital as the work itself. Recite Me aids in chronicling your accessibility journey and generating a balanced public statement, providing a robust, defensible record.
The bottom line
The AFIA Code does not demand perfection by October 1, 2026. It asks for reasonable measures utilizing appropriate standards and support systems for vulnerable clients. For most non-bank entities, the key question isn’t whether the website is flawless today, but whether you can demonstrate the sensible steps you are taking.
That inquiry is straightforward to answer, providing an ideal starting point. To evaluate your digital standing and determine appropriate actions for your organization, our team is ready to assist.
