Payment inclusion means everyone can pay and be paid, whatever their age, income, disability or attitude to digital tools. Since 28 June 2025, the European Accessibility Act covers payment terminals, ATMs, banking services and e-commerce, so the checkouts PSPs, PayFacs, ISOs and ISVs provide must comply. NORBr lets operators set that checkout and payment mix per merchant.
The industry tends to picture the excluded customer as someone without a bank account. Andréa Toucinho, Director of Studies, Prospective and Training at Partelya Consulting, draws a much wider circle: older people, people facing financial difficulties, people with disabilities, and people who choose not to pay digitally for privacy or security reasons. NORBr asked her to map that circle in Season 8 of #TheShot, because the checkout pages, payment links and terminals where inclusion is won or lost are run by PSPs, PayFacs, ISOs and ISVs on behalf of their merchants.
This article, updated in October 2026, follows the four episodes of Season 8 and adds the data and regulation behind them.
Key takeaways on payment inclusion:
- Exclusion in payments is broader than the unbanked: age, disability, financial fragility and distrust of digital tools all play a part.
- The European Accessibility Act has applied since 28 June 2025 to payment terminals, ATMs, banking services and e-commerce.
- EU countries approach inclusion through national payment actors, public programs or national payments committees.
- Inclusion by design, built into a project from the start, costs less than an accessible alternative added afterwards.
Who is excluded from digital payments in Europe?
Many more people than the industry assumes. Andréa lists four groups in Episode 1: older people who struggle with apps and authentication steps, people in financial difficulty, people with disabilities, and consumers who avoid digital payments because they worry about privacy or security.
The numbers behind each group are large. "Around 100 million people in the EU live with a disability," the European Commission said when the European Accessibility Act came into application. In the euro area, the ECB's 2024 study on consumer payment attitudes found that cash was still used in 52% of point-of-sale transactions, and that 62% of consumers considered it important to keep the option of paying in cash. Globally, the World Bank's Global Findex 2025 counts 1.3 billion adults still without access to financial services.
None of these people are edge cases for a merchant. They are customers who abandon a checkout that asks them to do something they cannot do.
What does the European Accessibility Act change for payments?
The European Accessibility Act, Directive (EU) 2019/882, sets common accessibility requirements for a list of products and services. According to the EU summary of the directive, it has applied since 28 June 2025 to payment terminals and self-service machines such as ATMs, and to consumer banking services and e-commerce. Microenterprises providing services are excluded.
In practice, a checkout page or a payment app must be usable with assistive technologies such as screen readers, readable without relying on color alone, operable without precise gestures, and understandable. For payment operators, the requirement lands in the components they provide to merchants: hosted payment pages, payment links, embedded checkouts and terminals. A merchant can hardly make its checkout accessible if the payment form it receives from its provider is not.
How do EU countries approach payment inclusion?
Inclusion is a shared priority, but each country works through different actors. In Episode 2, Andréa describes three models.
In the first, national payment actors invest in accessibility themselves. Portugal is her example, with an ATM network and the MB WAY mobile payment app built to serve the whole population. In the second, public programs carry the effort, such as Portugal Digital or Estonia's e-state strategy, which made digital public services the norm. In the third, national payments committees bring together banks, merchants, consumer groups and public authorities.
France and the Netherlands illustrate the third model. In the Netherlands, the National Forum on the Payment System chaired by De Nederlandsche Bank includes consumer and senior citizens' organizations, and its accessibility working group aims to keep payment services "accessible and available to all groups in society." In France, the national payments committee published a 2025-2030 national strategy for inclusive, sustainable and sovereign payments in October 2024, with the goal of better serving people with disabilities or limited digital literacy.
What does inclusion by design mean for payment products?
It means accessibility is a requirement from the first specification, not an alternative added once the product is live. In Episode 3, Andréa sets out three principles: inclusion by design, collaboration across the whole ecosystem rather than only banks and regulators, and freedom of choice, with cash kept as a payment option.
Retrofitting is expensive for a structural reason. A payment flow touches authentication, error messages, timeouts and confirmation screens. Making each of those accessible after launch means reopening every integration that depends on them, including the merchants' own. Building it in from the start means doing the work once, in the shared component.
The freedom of choice principle also explains why a broad mix of payment methods is an inclusion question as much as a conversion question. A customer who distrusts cards may use a bank transfer, a wallet or a local scheme. NORBr's case studies on the transition from cash to digital show how differently that shift happens from one country to another.
How can the payment industry build a more inclusive market?
Andréa's recommendations in Episode 4 are practical. Communicate better with end users about privacy and security, because distrust excludes as surely as disability. Share experience between EU countries rather than each reinventing its approach. Strengthen financial education, as Belgium, the Netherlands and Luxembourg already do in schools. Preserve freedom of choice and the role of cash.
What should PSPs, PayFacs and ISVs do now?
Treat accessibility as part of the payment product they deliver to merchants. That starts with an audit of the checkout components they provide, against the requirements of the directive and the harmonised standard EN 301 549, which builds on the WCAG guidelines, and continues with a payment method mix that lets each merchant serve customers who will not or cannot pay by card.
On NORBr's white-label payment infrastructure, an operator configures its checkout and the payment methods available to each merchant from one place, through the payment network it connects once. The checkout best practices guide covers the design side. Accessibility compliance remains a responsibility each operator assesses for its own products and markets, with its legal advisors.
Who is Andréa Toucinho?
Andréa Toucinho, Director of Studies, Prospective and Training, Partelya Consulting. Andréa is a consultant, speaker, journalist and author specializing in banking, payments, fintech and the European payments landscape. At Partelya Consulting, a payments consultancy, she leads studies, foresight and training, including a white paper on Buy Now, Pay Later that was the basis of her first #TheShot season, Season 5 on BNPL in Europe. She follows European payment regulation and market trends, from instant payments and EPI to PSD3. Follow her on LinkedIn and Partelya Consulting on LinkedIn.
When one adult in four in the EU lives with some form of disability, an inaccessible checkout is not a niche problem. It is a conversion problem that happens to be regulated.
NORBr is the white-label payment infrastructure for PayFacs, PSPs, ISOs and ISVs. Operators set the checkout and the payment methods each merchant offers, so every merchant can serve customers who do not all pay the same way.
About #TheShot: a video series sharing clear, unsponsored insights from payment professionals. One expert, one topic, short episodes. Watch Season 8 with Andréa Toucinho or browse all seasons.
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