ADA Title III prohibits discrimination in places of public accommodation. Banks are explicitly listed as covered entities. The question that occupied courts for years was whether websites qualify as places of public accommodation—or merely as extensions of physical branches.
That question is largely settled. DOJ has consistently taken the position in guidance letters, consent decrees, and settlement agreements that websites of covered entities must be accessible to people with disabilities. Multiple circuit courts have agreed, though the legal landscape varies somewhat by jurisdiction.
For banks specifically, this means:
- Your website is treated as an extension of your branch locations
- Online banking, loan applications, and account opening must be accessible
- Disclosures, forms, and PDFs published online carry the same obligation
- Mobile banking apps face the same accessibility requirements
The practical takeaway: DOJ expects banks to ensure their digital properties don't exclude people with disabilities. While Congress hasn't passed legislation specifying exact technical standards, DOJ settlements consistently reference WCAG (Web Content Accessibility Guidelines) as the measuring stick.
This is educational content—not legal advice. Consult qualified counsel regarding your institution's specific compliance obligations.