Cajasur is committed to making its products and services accessible, in accordance with national legislation (Law 11/2023) transposing Directive (EU) 2019/882 of the European Parliament and of the Council. This Accessibility Statement applies to the following channels:
- Websites (Cajasur – Online Banking)
- Websites (Cajasur – Public Website)
- Mobile applications (Apps)
- Automated teller machines (ATMs)
- Passbook updaters
- Cards
- Point of sale terminals (POS)
- Telephone service channel (Contact Centre)
- Contractual communications
- Non-contractual communications
- Built environment (Branches)
The Entity has also developed a specific Training Plan to train its staff on how to use accessible products and services.
1. INTRODUCTION
At Cajasur, accessibility is a core value that ensures everyone can access and enjoy our services in a simple, convenient and secure way. Recognising the diversity of our users, we are committed to providing an inclusive experience across all our customer service and communication channels.
This Accessibility Statement covers the various channels through which we interact with our customers, including our public and private websites, mobile apps, telephone customer service, ATMs, account statement updaters, cards and contractual documentation for consumer customers, as well as non-contractual communications such as emails, social media posts, radio adverts and text messages.
We have therefore implemented a comprehensive, systematic work plan aimed at progressively increasing the level of accessibility of each of these channels. This plan includes identifying and correcting barriers, implementing international best practices and providing ongoing training for our teams. Our goal is to create a fully accessible and satisfactory experience for all users.
2. COMPLIANCE STATUS AND NON-ACCESSIBLE CONTENT
At the Entity level, Cajasur is partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council and Law 11/2023 due to the exceptions and non-compliance of the aspects per channel indicated below:
2.1. Websites (Cajasur – Online Banking)
Cajasur's Online Banking has begun a process of implementation focused on significantly raising its level of accessibility. Thanks to this effort, Cajasur's Online Banking already satisfactorily complies with numerous requirements established in the UNE-EN 301549:2022 standard.
These actions reflect a solid commitment to digital accessibility and constitute a firm foundation for continuing to move towards an increasingly inclusive experience. The main aspects in which the site already guarantees an accessible and high-quality experience are presented below:
- The content is presented in a logical and meaningful sequence, respecting sensory characteristics and the various ways in which people can interact with the information. This ensures clear, focused and easy-to-understand navigation, adapted to different visual, auditory and cognitive abilities.
- It is ensured that understanding of the content does not depend exclusively on colour. In addition, text images are used in an accessible way, with high levels of contrast and effective management of content when the pointer is moved over or focus is received.
- Smooth, barrier-free navigation is provided, eliminating repetitive blocks that may hinder access. Each page has a clear and descriptive title, and various ways of accessing the information are provided. Consistent use of headings and labels organises the content, facilitating orientation and quick access.
- Keyboard interaction is fully enabled, with no focus traps or restrictions that limit access. The keyboard can access all interactive elements, which have a clearly visible focus. In addition, navigation remains stable, avoiding unwanted interruptions when receiving focus.
- Forms and input mechanisms clearly detect errors and offer useful suggestions so that users can easily correct them.
- The option to adjust text size has been implemented, allowing users to adapt the display to their readability needs without affecting the structure or functionality of the site.
- The site allows for adjustable interaction times, avoiding time limits that may hinder navigation or access to content.
- Links within the content are clearly defined and their purpose is understandable in context, facilitating informed and unambiguous navigation. This clarity allows all users, including those with assistive technologies, to understand the function and destination of each link without difficulty.
- The main language of each page and its specific sections is correctly identified, improving the experience of those who use screen readers, translation tools or have particular language needs.
- Multimedia content includes accessible alternatives, such as audio description or text equivalents, to ensure that all audio-visual information is accessible to users with sensory disabilities.
- The site respects user preferences and ensures compatibility with various devices and assistive technologies, guaranteeing that everyone can use the platform with their preferred equipment and settings.
- Status messages are communicated clearly and in a timely manner, informing users about relevant changes, processes or events during the interaction.
- Interaction with content is intuitive and accessible, for example in terms of focus and input.
- Navigation and content identification are consistent throughout the site, optimising usability and avoiding confusion.
These advances reflect a firm commitment to digital accessibility and constitute a solid foundation for further progress. As part of this continuous improvement approach, certain areas with potential for optimisation have been identified and are being addressed within an established Action Plan.
In this context, Cajasur Online Banking is partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council and Law 11/2023 due to the exceptions and non-compliance of the aspects indicated below:
- Non-compliance with Law 11/2023
- Alternative descriptions for non-textual content are being strengthened, ensuring that all visual and multimedia information is fully accessible to those who use assistive technologies. In addition, the structure and organisation of information continue to be improved to make it increasingly clear, intuitive and easy to understand for all users.
- The identification of the purpose of interactive fields and entries is being optimised, as are the descriptive labels associated with the elements. This allows users and assistive technologies to understand and use the content more easily and confidently.
- Improvements are being implemented in minimum contrast, as well as in text readjustment and spacing, to provide comfortable reading adapted to different needs and devices.
- The order of the navigation focus is being refined to make keyboard and assistive technology navigation consistent and natural, facilitating barrier-free navigation. Interactions when receiving input are also being adjusted to ensure they are intuitive, stable and free from interruptions.
- Labels, instructions and messages in forms are being enriched to guide users accurately. Furthermore, correct language specification is ensured in specific sections, promoting a personalised and accessible experience for multilingual users or those with special needs.
- Finally, the name, function and value attributes of interactive elements are being optimised, ensuring an inclusive and complete experience when using assistive technologies.
2.2. Websites (Cajasur – Public Website)
As with Online Banking, Cajasur's Public Website has embarked on a continuous process of accessibility improvements, with a commitment to making its digital content and services increasingly accessible to everyone.
This effort translates into the progressive implementation of measures and best practices that seek to eliminate barriers, facilitate navigation and ensure an inclusive and satisfactory experience for all users, regardless of their abilities or technological tools. Among the most notable improvements already available to users are the following:
- The synchronisation and preservation of subtitles and audio description is ensured in all audio-visual content, offering multimedia alternatives that allow people with visual and hearing impairments to access and fully understand the content without sensory barriers.
- Information is presented in a logical and orderly manner, making it easy to understand. In addition, sensory characteristics and orientation are clearly described, avoiding reliance on visual or auditory stimuli alone, which makes the experience more inclusive for people with sensory disabilities.
- The use of colour is controlled so that information does not depend solely on it, limiting images with text and maintaining good contrast in elements and focal points to facilitate visibility and accessibility.
- Keyboard navigation is comprehensive and unblocked, allowing full access for people with reduced mobility. Interaction times are adjustable to suit different paces and abilities.
- Each page has clear titles and multiple ways to access information. The visual focus is always visible to facilitate orientation, and the primary language is indicated to improve comprehension with assistive technologies.
- Interactions when focusing or entering data are intuitive and consistent, avoiding confusion. Navigation is consistent across all content, reducing cognitive load.
- Clear instructions are provided for correcting errors in forms, and information is presented in accordance with standards that ensure its correct interpretation by assistive technologies.
- Individual preferences are respected to personalise the experience, and compatibility is ensured for all devices and technologies with accessibility features for an inclusive, barrier-free experience.
Thanks to the progress made, we have taken significant steps towards greater accessibility. However, we are aware that there are still areas for improvement, which have already been incorporated into a defined Action Plan to continue raising accessibility standards across all our services.
In this regard, the Cajasur Public Website is partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council and Law 11/2023 due to the exceptions and non-compliance of the aspects indicated below:
- Non-compliance with Law 11/2023:
- Although progress has been made in synchronising and preserving subtitles and audio description, improvements are being implemented to optimise the playback of subtitles and audio description, as well as the controls for activating and deactivating them.
- Descriptions of non-text content are being enriched and the availability of recorded subtitles is being expanded, while the clear presentation of information and the relationships between its different elements are being improved. At the same time, work is being done to accurately identify the purpose of each interactive entry, promoting more intuitive and fluid navigation.
- In terms of visual accessibility, adjustments are being made to minimum contrast, resizing, reflow and text spacing. In addition, keyboard navigation is being refined to prevent blockages and ensure a logical and consistent focus order, while the contextual purpose of links and the structure of headings and labels are being optimised.
- Descriptive labels are being reinforced in interactive elements and the correct language specification is being ensured in all parts of the content. In addition, error identification is being improved, along with the clarity and accuracy of labels and instructions, so that users can interact with confidence and easily correct any incidents.
- Finally, the name, function and value attributes of interactive elements are being optimised, as well as status messages that report changes or actions taken. These improvements contribute to a more inclusive, intuitive and effective experience, especially for those who use assistive technologies.
2.3. Mobile applications
Accessibility has now become a fundamental aspect of mobile application development. Recognising the diversity of users and their different abilities, Cajasur's applications have begun to integrate improvements that facilitate usability for all people, including those with visual, hearing, motor or cognitive disabilities.
These improvements range from the use of colour and audio control to specific features that ensure comfortable and effective interaction. Below are some of the accessibility features that Cajasur's mobile apps have already begun to implement:
- The correct use of biometrics is guaranteed for secure and fast access to the app, allowing everyone, regardless of their abilities, to authenticate themselves easily and efficiently.
- The visual status and audio control are clear and adaptable, providing people with sensory disabilities with adjustable visual and audible signals that facilitate interaction and improve understanding of the information.
- Smooth interaction via the keyboard is guaranteed, allowing for controlled character repetition and double keystroke acceptance, avoiding lockouts or traps that may hinder navigation for people with reduced mobility or who use assistive technologies.
- A logical and meaningful sequence is maintained in the presentation of content, ensuring that sensory characteristics and orientation are clearly indicated, so that users can easily understand the purpose of each entry and navigate with ease and consistency.
- The use of colour, contrast and text images is carefully managed, ensuring that visual information is accessible and legible to all people, avoiding communication that relies exclusively on a single sensory resource.
- The contextual purpose of links, as well as headings and labels, is ensured to be descriptive and consistent, making it easy for users to understand and navigate the content with the help of assistive technologies in a clear and effective manner.
- The correct specification of the main language of the software is guaranteed, allowing assistive technologies to adapt their linguistic functions and facilitate the understanding of the content by users of different languages.
- Accessible and secure interaction is promoted when receiving input, providing clear identification of errors, status messages and precise instructions, and applying measures to prevent legal, financial or data-related errors, so that the experience is simple and reliable.
- Complete and consistent information is provided about interactive objects, their labelling relationships, and the list and execution of available actions, ensuring proper tracking and modification of focus and selection attributes, so that navigation is intuitive and efficient.
- Continuous and uninterrupted updating of statuses, properties, values, and text is guaranteed, ensuring that accessibility features are active and that users receive accurate information at all times during interaction.
- Clear detectability of all actionable elements and the issuance of timely status messages are ensured, making it easy for users to identify available options and understand the status of the application in real time.
- Full compatibility with accessibility features and assistive technologies is guaranteed, allowing the application to function properly with a variety of devices and services to provide an inclusive and barrier-free experience.
However, although significant progress has been made in implementing measures to ensure broad and effective accessibility in the application, areas for improvement have been identified and are already part of an Action Plan established to continue advancing this commitment.
Specifically, the mobile applications (Android and iOS) are partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council and Law 11/2023 due to the exceptions and non-compliance of the aspects indicated below:
- Non-compliance with Law 11/2023
- In the presentation of content, textual alternatives for images and important visual elements are being improved so that everyone, including those who use assistive technologies, can understand the information without relying exclusively on visual cues.
- To facilitate understanding, work is being done to strengthen the relationships between the different elements on the page. This helps to maintain a clear structure, avoiding confusion and improving the browsing experience.
- Colour contrasts and text size are being adjusted to ensure comfortable reading in different visual conditions. At the same time, the use of colour is being reviewed so that it is not the only resource used to convey information.
- In terms of navigation, issues with keyboard usage and focus order are being corrected. These improvements will allow users to move easily through all content without unexpected crashes or jumps, and with the focus always visible.
- Forms are also being improved with clearer labels and instructions. Messages are being added to help identify and correct errors, making interaction easier and more autonomous.
- In interactive elements, the information that assistive technologies need to correctly interpret their name, function and status is being reviewed. This will make it easy for users to know what each button, link or field does.
- For better compatibility with screen readers and other accessibility services, the relationships between different elements, such as menus and forms, are being refined to ensure logical and complete reading.
- Finally, improvements are being made to ensure that user preferences, such as language, contrast and display, are respected at all times. This helps to create a personalised and more comfortable experience for each individual.
However, it is important to note that, in the field of websites and mobile applications, certain content is not subject to applicable legislation. This includes the following:
- Office file formats published before the entry into force of Law 11/2023
- Pre-recorded time-based multimedia content published before the entry into force of Law 11/2023
- Content produced by third parties that is not financed, developed or controlled by the website operator
- Content on websites and mobile applications considered to be files, in the sense that they only contain content that is not updated or edited after 28 June 2025
2.4. Automated teller machines (ATMs)
With regard to ATMs, the measures already implemented by Cajasur to ensure an accessible, secure and equitable experience for all users, regardless of their specific abilities or needs, are detailed below:
- The visual content of the ATM is structured and designed to ensure readability and accessibility, using legible and appropriate fonts, allowing the text size to be changed up to 200% without loss of functionality, and ensuring a line spacing, paragraph spacing, letter spacing and word spacing structure that prevents loss of content or functionality when adjusted.
- The visual elements of the ATM offer an adequate contrast ratio with regard to adjacent colours (minimum 3:1) and when colour is used to convey information, a perceptible alternative that does not depend exclusively on colour is provided.
- The visual and interactive components of the ATM are arranged in a logical and consistent manner, receive focus in an order that preserves meaning and operability, and do not generate unexpected context changes when receiving focus.
- Clear and consistent labels, instructions and headings are provided for input and navigation fields. In the event of automatically detected errors, the system provides understandable feedback along with corrective suggestions, and if voice output is used, it explicitly identifies and describes the element where the error occurred.
- All non-text content has equivalent text alternatives, including special cases such as decorative content, logos, CAPTCHAs, sensory tests or user input, so that users with disabilities can access the same information.
- The ATM provides operating mechanisms that do not require a force greater than 22.2 N or complex simultaneous actions (such as grasping, pinching or twisting the wrist), and offers alternative modes of operation accessible to people with physical or coordination limitations.
- A physical numeric keypad with a rectangular layout is available, with the number 5 key tactilely differentiated for easy identification. The ATM does not require the user to connect, attach or install external assistive technologies, except for headphones or magnetic loops.
- The ATM screen is located at a height of between 800 mm and 1200 mm, with an angle of between 15° and 30°, and is visible from a point 1015 mm above the work area, ensuring legibility for users in different positions, including wheelchair users.
- If voice output is provided as a form of access, it can be interrupted or repeated by the user as necessary, is automatically interrupted by new actions or outputs, conveys all information necessary to complete or verify a transaction, and is provided in the same language as the visual content.
- The ATM is compatible with assistive hearing technologies such as hearing aids, telecoils and cochlear implants, and provides at least one mode of operation that does not require hearing.
- To prevent adverse effects on people with photosensitivity, the visual content of the ATM must not include flashes or rapid sequences of images that exceed safety thresholds.
- The ATM's accessibility features and modes guarantee the same level of privacy and confidentiality for users as conventional transactions.
Although significant progress has been made in terms of accessibility at ATMs, it is important to note that certain aspects still need to be improved to ensure a fully inclusive experience. These points have already been identified and incorporated into an Action Plan that will enable further progress to be made in this area.
For this reason, Cajasur ATMs are partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council, as well as with Law 11/2023, due to the exceptions and non-compliance of the aspects indicated below:
- Non-compliance with Law 11/2023:
- When instructions for use are not integrated into the ATM itself, there is an opportunity to strengthen alternative channels (such as websites), ensuring that they provide comprehensive, accessible and understandable information for all users.
- Audio-visual or audio-only content can benefit from the addition of subtitles, transcripts or alternative descriptions. This would help to make all information accessible regardless of the sensory channel used by the user.
- In certain cases, the contrast between the text (or visual elements) and the background can be optimised to improve readability. It would also be useful to make it easy to adjust the brightness and intensity of the screen and to ensure that it is positioned and oriented so that it is easily visible from different heights and positions.
- When instructions for use are not available directly at the ATM, they can be supplemented with a more detailed description of compatible assistive devices, available accessibility features and software and hardware characteristics.
- For transactions involving legal or financial commitments, it may be useful to implement data review, confirmation, and correction mechanisms, giving users greater control and security before finalising the transaction.
- When audio output is offered alongside visual content, it is recommended to improve synchronisation and correspondence between the two channels. In turn, it would be advisable to allow users to adjust the volume and speed of the audio, ensure that the volume is automatically reset after each use, and provide a clear tactile indication to start voice mode.
- Improving interaction time management could be beneficial, allowing the user to pause or extend time limits, as well as receive alerts through different sensory channels. In addition, content with movement or flashing should be able to be paused to avoid interference with other tasks.
- Actionable controls could be optimised by including options to identify them without executing them, and allowing users to activate accessibility features by means compatible with their abilities. It would also be useful for at least one of each type of actionable element to be located within the accessible height range from an unobstructed front view.
- For toggle controls, it would be advisable to ensure that the status can be perceived both visually and tactilely or audibly, depending on the user's preferred channel. This would promote a more inclusive and clear user experience.
2.5. Passbook updaters
Passbook updaters have also seen significant advances in accessibility, with the aim of making them easier to use for everyone, regardless of their abilities. The main achievements in this area are detailed below:
- Information on how to use the passbook updater is presented in clear, consistent language and a logical structure.
- Audio-visual content (videos with or without audio and audio-only content) has comprehensive accessible alternatives, such as audio descriptions, text or subtitles, which include all relevant information for all users.
- The text and text images on the updater interface use fonts with appropriate size, shape and contrast to ensure legibility and visual clarity, and the visual components maintain adequate contrast with adjacent colours.
- When colour is used to convey information, indicate actions or identify elements, the updater provides alternatives that do not depend on colour to ensure accessibility.
- Except in specific cases, all non-textual information has text alternatives that fulfil the same purpose, and when textual content is used to operate or communicate, non-textual alternatives are provided.
- The interface has a coherent and consistent order of components and mechanisms each time it is repeated, except for changes initiated by the user, and the headings and labels clearly describe the purpose to facilitate understanding.
- The updater offers alternative modes of operation that do not require hearing or speech. If a control requires more than 22.2 N of force, an alternative method requiring less force is provided. In addition, for operations that require simultaneous actions, there is at least one mode that does not require them, facilitating use by people with physical or motor limitations.
- At least one operable element of each type is located at an accessible height to facilitate physical access.
However, despite Cajasur's efforts to improve the accessibility of its passbook updaters, these devices are not yet compliant with the requirements set out in Directive (EU) 2019/882 of the European Parliament and of the Council, nor with Law 11/2023 due to the following aspects, which have already been identified and included in an Action Plan designed to correct these deficiencies and move towards regulatory compliance.
- Non-compliance with Law 11/2023
- With regard to information on the use of the passbook updater, opportunities have been identified to ensure that it does not rely exclusively on sensory characteristics such as colour, shape or sound, which would make it easier to understand and operate for users with different abilities.
- When instructions are not found directly on the machine, it would be advisable to offer accessible alternatives, such as a website, which present the information in a clear, understandable and adaptable way to different sensory channels, thus promoting an inclusive experience.
- The presentation and wording of the instructions could benefit from more consistent and structured language, which would facilitate understanding, especially for people with intellectual disabilities.
- The accessibility of audio-visual content could be improved by incorporating subtitles, audio descriptions and full text versions, ensuring that all information is available to users with visual or hearing impairments.
- The updater could optimise accessibility by providing voice output for non-textual information stored on the machine itself, facilitating access for people with visual impairments without the need for additional devices.
- It would be beneficial to expand compatibility with assistive devices, providing detailed information on compatible devices and the tests carried out, to ensure effective use with assistive technologies.
- Audio-related controls, such as volume and playback speed, could be improved to facilitate a personalised and accessible experience, avoiding sound interference and promoting better coordination with visual information.
- Some controls and actionable elements are not easily detectable without prior interaction or do not have alternative touch or sound modes, which could make them difficult to use for people with visual impairments. Improving this and providing multi-channel feedback would enhance usability and accessibility.
2.6. Cards
In view of the entry into force of accessibility regulations on 28 June 2025, Cajasur cards have begun to incorporate significant improvements in accessibility, with the aim of ensuring that everyone, regardless of their abilities, can use them effectively and independently.
In this way, Cajasur is moving towards a more inclusive design that meets the needs of a wide range of users, promoting equal access and autonomy in the use of these essential everyday products. The main advances implemented are highlighted below:
- The Bank currently offers accessible versions of its main products (Visa Debit, Visa Dual, Visa Classic and Visa Gold), which include features such as notches, high contrast and directional arrows.
- The font sizes on the back of the card have been adapted to comply with accessibility regulations.
- A customisable plastic card model in Braille has been purchased and will be available on request for all Visa card products from the date the regulations come into force.
- As part of the customer information process, a specific landing page has been developed on the Cajasur website, which includes a description of the accessible features incorporated into the cards. This information will be accessible via a QR code included in the documentation accompanying the card (e.g. card carriers when renewed, card carriers in card applications with home delivery, or card transaction documents).
- Card carriers are being adapted to comply with accessibility requirements in terms of contrast, text size and legibility.
- Instructions on how to use the card are provided on the card itself or, failing that, in supporting documentation and websites. These instructions do not rely solely on sensory characteristics such as shape, colour, size or sound, and are presented in clear, consistent and logically structured language to facilitate understanding by people with intellectual disabilities.
- The text and text images on the card, documentation and website use fonts with appropriate size, shape and contrast to promote readability and visual clarity. However, not all cards fully comply with these recommendations, nor do all visual components maintain the minimum contrast with adjacent colours.
- The text of the instructions can be enlarged up to 200% without loss of content or functionality, and style properties such as line spacing and spacing between letters, words and paragraphs are configured to maintain accessibility.
- Alternative instructions on digital channels are available in formats that facilitate the generation of accessible versions for different sensory channels, such as screen readers, and with a few exceptions, all non-textual information has textual alternatives that serve the same purpose. However, not all cards fully comply with this criterion.
- Dynamic or moving information in documentation or on the web can be paused, stopped or hidden to avoid distractions, except when movement is an essential part of the function.
- Headings and labels in documentation clearly and consistently describe the purpose or topic to facilitate navigation and understanding, although this practice is not universal across all cards.
- When information is presented in text format, non-text alternatives are provided, such as Braille, relief or audible QR codes, to ensure accessibility. Accessible cards include tactile elements that allow them to be identified and oriented for insertion according to specific criteria; however, this feature is not present on all cards.
Although Cajasur cards have made considerable progress in implementing accessibility improvements, there are still areas where certain deficiencies have been identified. These gaps, although limited, point to specific areas where the cards do not fully comply with the established requirements, such as consistency in the presentation of instructions or the availability of alternative formats across all sensory channels. Cajasur's Action Plan specifically addresses these areas in order to continue progressing towards a fully inclusive design.
As a consequence, the cards are partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council, as well as with Law 11/2023, due to the exceptions and non-compliance of the aspects indicated below:
- Non-compliance with Law 11/2023
- Instructions on how to use the card are not always provided in alternative formats that specifically describe the card's accessible features, limiting the information available to users with special needs.
- The presentation and wording of the instructions lack consistent and structured language that facilitates understanding, making access particularly difficult for people with intellectual disabilities.
- Some text and images on the card do not meet the minimum contrast level required to ensure legibility, affecting visibility for users with low vision or colour blindness.
- Not all non-textual information presented to the user has equivalent textual alternatives, which may leave people who rely on assistive technologies unable to access certain content.
- Alternatives for non-textual content do not always include adequate descriptive identifiers or alternative forms for different sensory modalities, limiting accessibility for users with various disabilities.
2.7. Point of sale terminals (POS)
This channel has a different structure in its Statement compared to other products, due to the specific management of POS terminals at Cajasur:
- With regard to physical POS terminals, a distinction is made between Géminis POS terminals, which are owned by Redsys and managed on a leasing basis, and those belonging to the merchant, where Cajasur is only responsible for processing payments.
- As for virtual POS terminals, a distinction is made between those that operate by redirection (where, at the time of payment, the customer is directed to a website managed by Redsys to complete the transaction) and those with other configurations, such as REST Insite integration or processing through PSPs, among others.
In this context, Redsys has informed its customers that it is implementing the necessary adaptations to its Android terminals to comply with accessibility regulations. Currently, this technology represents a minority proportion of the Cajasur Group's card terminals, with a penetration rate of less than 10%.
Although Redsys is responsible for managing POS terminals, Cajasur has included various measures in its Action Plan to ensure, as far as possible, that the external provider complies with current regulations:
- Transfer of the minimum accessibility requirements and controls that Redsys must implement, both on physical POS terminals and on websites associated with virtual POS terminals.
- Inclusion of specific clauses in future contracts with Redsys or other providers that require the incorporation of accessibility features in accordance with Law 11/2023.
- As a best practice, requesting customers who contract the payment gateway to ensure that the POS terminal complies with the accessibility requirements established in Law 11/2023.
- Transfer of minimum accessibility requirements to Diusframi and the Basque Government so that they can adapt their POS terminal applications to established software standards.
2.8. Telephone service (Contact Centre)
Cajasur has also implemented several measures to improve the accessibility of its Contact Center services, with the aim of ensuring that all people, regardless of their abilities, can use them effectively and autonomously.
These improvements cover key aspects such as activation of accessible functions, availability of alternative modes of interaction, clarity and readability of information, as well as adaptation to various sensory and motor needs. The following are key developments that reflect Cajasur’s commitment to inclusion and accessibility in its customer service channels:
- Accessibility features available in Contact Center services are guaranteed to be enabled. In addition, where manual actions are required, at least one way of performing the functions is provided by alternative actions that do not require fine motor control or manipulation skills.
- Alternative operation modes that do not require hearing are offered, providing equivalent visual information when there is sound output, and an input mechanism that does not depend on the use of voice when it is necessary for interaction. It also ensures that users can access information and perform tasks without the need for hearing or voice.
- The information provided is understandable and kept within the B2 level to facilitate understanding. In addition, this information is organized in a logical and meaningful sequence that facilitates the understanding of available messages and options.
- All interactive elements and system options have descriptive names that clearly communicate their purpose, ensuring intuitive navigation for all users.
- When a mode of operation requires simultaneous actions, an alternative that does not require this type of interaction is provided, making it easier to use for people with motor limitations.
- To avoid auditory confusion, the sound outputs are checked to not reproduce interference noises lasting more than three seconds and that the voice outputs are interrupted when the user proceeds or when a new output starts.
- Errors detected in data entry are clearly communicated to the user, and where suggestions for correction exist, they are provided in a consistent manner unless they may compromise the security of the content.
- Instructions on the use of the services are provided in legible sources and with a minimum contrast ratio of 4.5:1, except in specific cases.
- The functionality of the interface is completely keyboard-based, without requiring a minimum speed for keystrokes, except in functions that depend on the continuous movement of the user.
- Changes in the state of any component of the interface do not cause automatic modifications in the context without the user having been previously informed, avoiding disorientation or loss of control.
Although Cajasur has made significant progress in implementing improvements to ensure accessibility in its Contact Center services, there are still some areas where full compliance with current regulations has not been achieved. The Cajasur Action Plan includes specific measures to address these shortcomings and move towards a more accessible and inclusive service.
For this reason, the Cajasur Contact Center is partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council as well as with Law 11/2023, due to the exceptions and non-conformity of the following aspects:
- Lack of conformity with Law 11/2023
- It would be advisable to strengthen the availability of accessible information on Contact Centre products and services, as well as their compatibility with assistive technologies. It would also be advisable to improve the electronic presentation of this information in order to make it clearer, more coherent and easier to understand.
- In attention channels that use audio, such as IVR, the incorporation of speed controls could be considered to facilitate the understanding of the content. It would also be useful to review the management of software time limits, allowing them to be adjusted, stopped or extended when technically feasible.
- Opportunities have been identified for improving the behaviour of interfaces, which in some cases can modify accessibility functions without user intervention. In addition, ensuring continuous staff training on accessibility issues, attention to diversity and use of clear language could strengthen the quality of service offered.
2.9. Contractual communications
In compliance with current accessibility regulations, contracts relating to new banking services entered into with consumers on or after 28 June 2025 must be accessible. A transitional period until 28 June 2030 is also established to adapt service contracts in force on that date.
In the contractual communications channel, the main accessibility requirements focus on the use of clear and understandable language, with a level of complexity not exceeding B2 of the Common European Framework of Reference for Languages (CEFR). In addition, specific criteria are required regarding the format of the text, such as font size and line spacing, and the correct structuring and coding of PDF documents, in accordance with technical accessibility standards.
No specific prior assessment of the channel has been carried out, as it was decided to move directly to the implementation phase of the adaptation measures, which focus on simplifying the language and improving the document format. This strategy has made it possible to speed up progress towards regulatory compliance, although it is estimated that the overall level of compliance of the channel can still be considered limited, especially with regard to the accessible technical structure of all documents.
In this context, Cajasur has begun adapting its contractual framework in order to comply with the requirements established by current regulations. This process is being carried out progressively, prioritising documents based on their relevance to the volume of business and the internal operational needs of the Entity.
The contracts considered to be a priority — i.e. those with the greatest impact — have already been updated.
The rest of the pre-contractual and contractual communications included in the scope of the regulations in force as of 28 June 2025 are in the process of being adapted, which will be carried out progressively in accordance with the established plan.
2.10. Non-contractual communications
Cajasur's non-contractual communication channels have incorporated various improvements to ensure inclusive and understandable access for all users.
The main accessibility compliance features of various non-contractual communications are detailed below, with the aim of facilitating understanding, interaction and access to information for people with different abilities and sensory needs:
- The various digital communication formats comply with essential accessibility criteria, ensuring an inclusive experience for all users. Emails, social media posts, videos, radio pieces and SMS messages have a logical and meaningful sequence that facilitates understanding, use clear and consistent headings and labels that describe the content or purpose, and use text in legible fonts and of an appropriate size to aid readability.
- In addition, they ensure adequate levels of contrast in text and images, offer non-text alternatives when textual content conveys information, and provide text equivalents for all non-textual content. The videos include subtitles in pre-recorded audio and control flashes to avoid photosensitive risks, while radio pieces and SMS messages maintain a level of complexity no higher than B2.
- Finally, all information is available in accessible formats that allow it to be presented in different modes and sensory channels, ensuring that it is perceptible, manageable, understandable and robust for all users.
Although the non-contractual communications channel complies with a wide range of key accessibility requirements, a number of non-compliances have been identified that affect its overall compliance. The Action Plan includes measures to correct these shortcomings and strengthen the accessibility of this channel, with the aim of ensuring an inclusive experience for all users.
These shortcomings, although they do not invalidate all the progress made, mean that non-contractual communications are only partially compliant with Directive (EU) 2019/882 of the European Parliament and of the Council, as well as with Law 11/2023, due to the exceptions and non-compliance of the aspects indicated below:
- Non-compliance with Law 11/2023
- Although efforts have been made to communicate through various media, there is still room for improvement in terms of clarity and accessibility of information. In emails, videos and social media posts, progress could be made in offering clearer messages tailored to an intermediate reading level, as well as including descriptive alternatives for non-textual elements to facilitate access through assistive technologies. It would also be valuable to provide more details about how the service works, its relationship with the products used and its accessibility and interoperability features with assistive devices.
- Similarly, in radio pieces and SMS, there is room to strengthen accessible and understandable information, which would contribute to a more inclusive experience for all people, especially those who use special devices or aids. These improvements will enhance communication and make services more accessible to everyone.
2.11. Built environment (Branches)
In addition to improving accessibility in its products and digital channels, Cajasur has carried out a comprehensive analysis of its physical branches to ensure compliance with current Spanish regulations on accessibility in the built environment. In this area, the main regulatory reference is the Technical Building Code (CTE), with special attention to Basic Document DB SUA 9, which establishes the applicable accessibility criteria.
Buildings and establishments for which a building permit was applied for after 12 September 2010 are considered to comply with the requirements established in the CTE, given that its application is mandatory for obtaining activity licences from that date onwards. Therefore, these branches are in line with the accessibility provisions for built environments set out in Law 11/2023.
For those offices whose building permit application was submitted before that date, a specific analysis has been carried out in order to assess their current level of accessibility and define the actions necessary to move towards a more inclusive and accessible environment for all people. Based on the results obtained, Cajasur has implemented a series of specific improvements in its branches.
Although significant progress has been made in terms of accessibility in its branches, the study has identified new opportunities for improvement, especially in those offices built before the mandatory entry into force of the Technical Building Code (CTE).
As a result of this analysis, Cajasur has designed an Action Plan that includes the improvements identified and establishes their progressive implementation, with the aim of ensuring increasingly accessible, inclusive and safe environments for all users.
This plan provides for future office renovations to incorporate the necessary adaptations during the period 2025–2029. In addition, a prioritisation of interventions has been established, anticipating that the first actions will be carried out between 2025 and 2027, in coordination with the Entity's Strategic Plan for branches.
2.12. Training on accessibility
Article 15 of Law 11/2023 requires that "service providers must ensure adequate and ongoing training for their staff to ensure that they acquire knowledge on how to use accessible products and services. This training must include issues such as the provision of information, advice, advertising and attention to diversity".
In response to this regulatory requirement, Cajasur has made specific training on accessibility available to its staff since the first quarter of 2025 as part of the Bank's annual Continuing Education Programme.
The development of a training plan is not only a task carried out to comply with accessibility regulations, but the Entity also considers it relevant to improving the level of service perceived by users.
3. PREPARATION OF THIS ACCESSIBILITY STATEMENT
This statement was prepared on [28/06/2025].
The method used to prepare the statement was a self-assessment carried out by the organisation itself.
Last review of the statement: [28/06/2025]
4. COMMENTS AND CONTACT DETAILS
You can communicate with us about accessibility requirements, such as:
- Reporting any possible non-compliance.
- Reporting other access difficulties.
- Making any other queries or suggestions for improvement regarding the accessibility of the organisation.
Through the organisation's usual Customer Service channels.