The EAA asks banks to write at level B2
The only reading level in EU accessibility law is borrowed from language teaching. Readability formulas don't map to it, and no regulator has said how to check it.
One line in the European Accessibility Act sets a reading level. Annex I, consumer banking services: the information has to be understandable "without exceeding a level of complexity superior to level B2 (upper intermediate) of the Council of Europe's Common European Framework of Reference for Languages." B2 appears nowhere else in the directive.
Consumer banking here means credit agreements, payment services, payment accounts, e-money and some investment services. Germany carries the line in § 17 of the BFSGV and narrows it to "Informationen zur Funktionsweise der Bankdienstleistung," information about how the service works. The official explanation adds two edges. The contract documents themselves don't have to meet it, but the essential content of the contract has to be explained. And lower than B2 is allowed: "Grundsätzlich ist es im Hinblick auf eine gute Verständlichkeit sinnvoll, ein möglichst niedriges Sprachniveau zu wählen." As low as possible.
Who is B2, exactly?
The CEFR levels describe people learning a foreign language. B2 is someone who "can understand the main ideas of complex text on both concrete and abstract topics." That is a description of a reader. The directive applies it to a text: a scale built for people learning a language, used for people reading their own.
The German banking associations said so in 2022, in their comment on the draft: "keine konkreten Anforderungen an das Sprachniveau B2 existieren," and the definition aims at understanding "einer anderen Sprache als das der Muttersprache." In the Dutch consultation, the banks asked which language level was meant. The answer was the directive's.
Readability scores don't translate
The obvious tool is a readability formula. Flesch was calibrated on English and American school grades, Amstad is its German adaptation. Neither has a validated mapping to CEFR levels. In a 2011 study on texts for second-language readers, Flesch Reading Ease put 44 percent of the texts into the right level. For intermediate texts, the band B2 sits in, it was 18 percent.
(The plain-language standard ISO 24495-1 exists, and Germany has DIN 8581-1 for Einfache Sprache. Neither is mapped to CEFR levels either, at least not anywhere I could find.)
What a bank can do
No regulator has published a method for checking B2. That leaves a direction without a test. Write the explanation of how the account, the loan or the payment works in short sentences, with the terms defined where they first appear. Then give it to people who match the description, someone who reads the language well but not natively, and see what they get wrong.
The German explanation already says which way to go. As low as possible is a level you can check by watching someone read.