Your Website Is a Consumer Duty Problem: Accessibility, Vulnerable Clients and the Ageing Adviser Site

Two separate pressures have converged on the same page, and most independent adviser firms have noticed neither.

The first is regulatory expectation around consumer understanding and vulnerable customers — the requirement that communications be clear, that firms consider the needs of customers with characteristics of vulnerability, and that outcomes be evidenced rather than assumed.

The second is accessibility standards. The European Accessibility Act took effect in mid-2025, bringing WCAG 2.2 conformance into scope for a wide range of consumer-facing digital services, including many financial services. UK firms are affected wherever they serve customers in EU member states, and separately UK equality legislation has always required reasonable adjustments — a duty that has been enforced against inaccessible websites for years.

Now consider who reads an adviser’s website.

The demographic overlap nobody mentions

Around sixty-nine per cent of advised clients’ primary objectives concern pensions and retirement. Later-life lending is one of the FCA’s stated priority themes in the mortgage rule review, alongside support for older borrowers and consumers with variable incomes or past credit difficulty.

In other words, the core audience for an independent IFA or mortgage broker skews substantially towards people aged fifty-five and over — precisely the group most likely to experience reduced visual acuity, reduced fine motor control, or to be reading on a phone in poor light while managing a bereavement, a divorce or a health event.

An adviser website is not an edge case for accessibility. It is close to the central case.

What typically fails on an adviser site

These are not exotic problems. They are the standard output of a template site built five or more years ago and never revisited.

Text contrast. Light grey body text on white is the single most common failure on professional services websites. It looks refined on a designer’s calibrated monitor. It is unreadable on a phone outdoors at sixty-eight.

Text that cannot be enlarged. Fixed sizing, or layouts that break when a user increases text size, forcing horizontal scrolling.

Forms without proper labels. Placeholder text used instead of labels disappears the moment someone starts typing — a serious problem for anyone using a screen reader, and a mild irritation for everyone else.

Unlabelled links and buttons. “Click here”, “Read more”, “Find out more” repeated fifteen times conveys nothing to a screen reader user navigating by link list.

PDFs as the only route to information. Fee schedules, service summaries and terms of business published as scanned or untagged PDFs are frequently inaccessible, unsearchable, and invisible to search engines.

No keyboard navigation. Menus and forms that only work with a mouse.

Poor target sizes. Small tap targets close together — a WCAG 2.2 addition specifically addressing motor difficulty and mobile use.

Video without captions. Increasingly common on adviser sites and increasingly often unusable.

Why this is a commercial issue before it is a compliance issue

It is tempting to file accessibility under risk management and defer it. That misreads what is actually happening.

An older prospect who cannot read your fee page does not file a complaint. They leave. A borrower approaching retirement who cannot complete your enquiry form on a phone does not email to explain. They call a broker whose form works. Every accessibility failure is simultaneously a conversion failure, and it is concentrated in exactly the demographic with the largest assets and the greatest need for advice.

There is a second-order benefit as well. Accessible sites are structurally clearer sites — proper headings, semantic markup, real text rather than text baked into images, descriptive links. That is also what search engines and AI answer systems need in order to parse and cite a page. Firms who fix accessibility frequently find their search visibility improves as a side effect.

The Consumer Duty angle

Consumer understanding is not confined to suitability reports and client agreements. Your website is a communication with retail customers and prospective customers, and it is very often the first one. If it is difficult to read, if the charging structure is opaque or absent, if the description of your service is vague, or if a person with a common impairment cannot use it, that is difficult to reconcile with an obligation to support customer understanding and to consider vulnerability.

Firms invest considerable effort evidencing good outcomes in the advice process, and then leave the front door in a state they would never accept in a suitability letter.

What to check this week, free

Five things any adviser can assess without a specialist:

  1. Open your site on a phone, outdoors, in daylight. If you are squinting at the body text, your clients certainly are.
  2. Increase your browser text size to 200%. Does the layout survive, or does content overlap and disappear?
  3. Try to complete your own enquiry form using only the keyboard — tab, arrow keys, enter. No mouse.
  4. Run your homepage and fee page through a free automated accessibility checker. It will not catch everything, but the failures it does catch are real.
  5. Check whether your key information exists as a web page, not only as a PDF.

Automated tools typically catch perhaps a third of real-world issues, so a clean report is not a clean bill of health. But a failing report is unambiguous.

Fixing it in the right order

For a site more than a few years old, patching accessibility onto an ageing template is usually poor value. Contrast, type sizing, tap targets, form structure and heading hierarchy are all design-layer decisions. It is generally cheaper and better to resolve them in a new design than to retrofit them into an old one.

Heer Digital builds independent IFAs and mortgage brokers a working homepage prototype at no cost and no obligation — designed from the outset around readable contrast, sensible type sizing, proper heading structure, keyboard-navigable forms and generous tap targets. You can open it on your own phone, outdoors, and compare.

From there, the build fits the firm. A fast, low-cost site with no content management system keeps a small practice accessible and quick with almost nothing to maintain. Converting the prototype into WordPress suits firms that need to publish, add adviser profiles and manage regulatory documents as proper web pages rather than PDFs — with accessible patterns built into the templates so future content stays compliant by default.

Your website is being read by the people these standards exist for. It should be the easiest thing your clients deal with all week.

Contact Heer Digital for a no-cost, no-obligation homepage prototype built to be readable, usable and fast.

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