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Law 232/2022 and Deaf Customers: What Banks, Institutions, and Companies Must Do

A deaf customer using sign language at a bank counter.

Starting June 28, 2025, banks, telecommunications providers, online stores, and transportation companies in Romania must make their services accessible to people with disabilities. This requirement stems from Law No. 232/2022, Romania’s implementation of the European Accessibility Act.

For a deaf or mute customer, this changes one simple thing: it is no longer acceptable for the only way to resolve an issue to be “call the call center.” Below you’ll find what the law requires, who enforces it, what risks a company faces, and the specific steps an organization can take, starting today, to communicate with customers who cannot hear or speak.

What Is Law No. 232/2022

Law No. 232 of July 19, 2022, transposes Directive (EU) 2019/882, known as the European Accessibility Act (EAA), into Romanian law. It was published in the Official Gazette No. 743 of July 25, 2022, and takes effect on June 28, 2025—the same date as in all EU member states.

The law establishes accessibility requirements for certain consumer products and services. Its purpose is to ensure that a person with a disability can use these services independently: to perceive, understand, and operate them without relying on anyone else.

Important dates:

DateWhat happens
June 28, 2025The law applies to products and services offered to consumers
June 28, 2027Provisions regarding 112 emergency calls take effect
June 28, 2030The transition period ends for services that use products put into service before 2025 and for existing contracts

Who Is Subject to This Law

The law applies to companies that offer consumers the following services:

  • consumer banking services (accounts, cards, loans, internet and mobile banking);
  • electronic communications services (telephone, internet, messaging);
  • e-commerce (online stores and their apps);
  • passenger transportation by air, rail, sea, and bus: websites, apps, e-tickets, travel information, and self-service kiosks;
  • access to audiovisual media services, e-books, and dedicated software.

The law also covers products: computers, phones, tablets, payment terminals, ATMs, and ticket vending machines.

Exception for micro-enterprises. Companies that provide services and have fewer than 10 employees and an annual turnover below the equivalent of 2 million euros are exempt from accessibility requirements. There is also an “undue burden” exception: a company may argue that making the necessary adjustments would entail excessive costs. However, it must conduct and document an assessment, which the authorities may request.

For a bank, a telephone operator, or a retail chain, these exceptions practically do not apply.

What This Means in Practice for Deaf and Mute Customers

For people with hearing or speech impairments, the most direct requirement concerns communication. Electronic communications services must provide real-time text and, where video is available, “total conversation”: voice, text, and video synchronized within the same call. Terminal equipment must be capable of processing real-time text.

In practice, a customer who cannot hear or speak should be able to:

  • read what is being said to them, not just listen (captions, transcripts, real-time text);
  • respond in writing when they cannot speak, and have their message reach the other person;
  • handle the same tasks as other customers on the website, in the app, and through support, without needing a family member to “call on their behalf”;
  • receive service information through at least two sensory channels, such as text and audio.

An important detail: the law focuses on digital channels and products. It does not regulate face-to-face interactions at the service counter in detail. However, a deaf customer who visits the agency faces the same problem as they would on the phone. An institution that addresses digital communication but leaves the customer on their own at the service counter has not truly resolved accessibility.

Who Monitors Compliance and What Are the Risks for Companies

Enforcement is divided among several authorities, depending on the sector:

FieldAuthority
Consumer banking services, equipment, e-book readersANPC
Electronic communications servicesANCOM
E-commerce, websites and mobile apps, e-booksADR (Romanian Digitalization Authority)
Audiovisual media servicesCNA
Transportation information and self-service kiosks in transportationMinistry of Transportation and Infrastructure
Payment terminals and electronic ticketsMinistry of Economy

Fines prescribed by law range from 5,000 to 15,000 lei, depending on the violation. In addition to the fine, authorities may impose additional measures: withdrawal of the product from the market, suspension of operations, or revocation of licenses.

For a bank, the fine itself is small. The real risk is reputational and legal: complaints to the National Council for Combating Discrimination (CNCD) for discrimination, repeated inspections, and lost customers. And a deaf customer who cannot manage on their own does not leave alone: their family usually leaves with them.

Practical Steps for an Institution

A bank, a university, or a service provider can start with these steps:

  1. Take stock of the channels through which customers contact you: in-person, phone, call center, chat, email, app, website. For each one, ask: Can a deaf customer use it on their own? What about one who doesn’t speak?
  2. Check your website and app against the EN 301 549 standard (essentially, WCAG 2.1 Level AA): captions for videos, contrast, mouse-free navigation, clear forms.
  3. Offer a text-based alternative for every voice-based channel. If the only way to unblock a card is by phone, a deaf customer is left out.
  4. Address face-to-face interactions at the counter: use a screen or tablet that transcribes what the clerk says and reads aloud what the customer types.
  5. Train your staff. A few simple rules make a big difference: face the customer, not the monitor; don’t raise your voice; and check to make sure you’ve been understood.
  6. Publish accessibility information (an accessibility statement), as required by law, and document what you’ve done in case of inspections.
  7. Test with real users. Invite an association of deaf people to try out your services and listen to their feedback.
  8. ☐ Inventory of contact channels
  9. ☐ Website and app audit (EN 301 549 / WCAG 2.1 AA)
  10. ☐ Written alternative for each voice channel
  11. ☐ In-person service solution
  12. ☐ Staff training
  13. ☐ Published accessibility statement
  14. ☐ Testing with deaf and mute users

Where Votrix Helps

Votrix solves the hardest part: live conversation—whether in person or over the phone—with a customer who cannot hear or speak. The app converts speech to text and the customer’s written text to speech, in real time. If needed, it also translates between languages. And because Votrix can run entirely on your own hardware — on-premises with Votrix PC, or on-device on a phone or laptop — the conversation stays inside your institution and nothing is sent to an external cloud. For banks, hospitals, and public bodies this data sovereignty is the most important part: you serve deaf and foreign-language customers without ever exposing their personal data to a third party.

ScenarioThe Votrix Solution
Deaf or non-verbal customer at the service counterVotrix Share: the staff member speaks, the customer reads on the screen; the customer types, the app reads it aloud
Meetings, classes, and sessions with multiple participantsVotrix Teams: captioning and translation for groups
Phone call with a customer who cannot hear or speakVotrix Call: the call is transcribed and played back in both directions
Organizations that want data to remain on their own networkVotrix PC: on-premises installation, with Share and Teams licenses for employees

What the institution actually gets:

  • a solution it can deploy at the service counter starting tomorrow, on a tablet or an existing PC;
  • communication with foreign customers as well, not just those who are deaf or mute;
  • full information sovereignty: with Votrix PC (on-premises) or on-device processing, the conversation never leaves your own network — critical for institutions that handle sensitive data;
  • no mandatory subscription and no metered hours when you run on your own hardware (Votrix PC or an on-device model); hourly packages apply only if you choose to use Votrix’s cloud servers. Special pricing is available for associations of deaf and mute individuals.

Votrix alone does not make an institution compliant with Law 232/2022: the website, app, and procedures must be verified separately. However, it addresses precisely the aspect that a website audit does not cover: the moment when a deaf or mute person actually needs to speak with you.

Request a Votrix demo for your organization

Frequently Asked Questions

When does Law 232/2022 take effect? June 28, 2025. The provisions regarding 112 calls take effect on June 28, 2027, and some transition periods last until 2030.

Does this apply to small businesses as well? Microenterprises that provide services (fewer than 10 employees and a turnover below the equivalent of 2 million euros) are exempt from the accessibility requirements. Larger companies may invoke “disproportionate burden” only with a documented assessment.

What fines does the law provide for? Between 6,000 and 15,000 lei, depending on the obligation violated. This may be accompanied by product recalls or suspension of operations.

Who oversees the banks? ANPC monitors banking services for consumers. ANCOM monitors electronic communications services, and ADR monitors websites, apps, and e-commerce.

Is an accessible website enough? No. Deaf and mute customers must also be able to use other channels: the phone, customer support, and, essentially, the teller window. A perfect website doesn’t help a customer who has to call to unblock their card.

What is “real-time text”? It is text transmitted character by character, as it is typed, during a conversation. The law requires electronic communications services to provide this so that people who cannot hear or speak can converse without delay.

Sources

This article is for informational purposes only and does not constitute legal advice. For your institution’s specific situation, consult a specialized attorney.

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