The Gap Between State Bank Policy and Lived Reality for Blind and Low-Vision Account Holders
A Research and Policy Brief prepared by Laiba Usman
Abstract
Pakistan’s central bank has issued accessible-banking guidance since 2009 and, since 2021, a binding, board-level policy requiring accessibility infrastructure, staff training, and model branches for persons with disabilities. Despite this regulatory record, survey evidence indicates that only 17 percent of blind and low-vision banking users can operate an ATM without assistance, and a majority are initially denied accessible services when they request them in person. This brief traces the regulatory history of disability-inclusive banking in Pakistan, examines survey and testimonial evidence of the implementation gap, compares Pakistan’s position to India’s regional experience with talking ATMs and Braille-marked debit cards, and closes with concrete, actor-specific recommendations for banks, the State Bank of Pakistan, and disability advocates.
Keywords: blind banking accessibility Pakistan; ATM accessibility; visually impaired banking; State Bank of Pakistan disability policy; financial inclusion; assistive technology
KEY FINDINGS AT A GLANCE
| 17% can use an ATM unaided | 58% denied accessible service on first request at a branch | 45% had to escalate to senior bank officials | 25% rated their bank’s app fully accessible |
Source: survey of 120 blind and low-vision banking users in Pakistan, as reported in Shabbir (2026); see Note on Sources and Methodology.
1. Introduction
Salman Khalid teaches at a college in Lahore. He moves through the city independently, guided by sound, memory, and the tap of his cane. But there is one trip he makes for a different reason: a journey across a city of more than thirteen million people to reach the single automated teller machine, on Mall Road, that he can operate without a stranger’s help. When he finds it, he withdraws his own cash privately, without disclosing his PIN to anyone. For most account holders this would be unremarkable. For Salman, it is the entire point of the journey (Shabbir, 2026).
His experience is not an outlier. It is close to the norm for Pakistan’s blind and low-vision banking customers, more than a decade after the State Bank of Pakistan (SBP) first issued guidance intended to prevent exactly this outcome. This brief examines the distance between that regulatory intent and everyday practice: what the policy record actually requires, what survey and testimonial evidence shows about implementation, how a comparable market has approached the same problem, and what would need to change for policy to translate into practice.
2. Regulatory Background: State Bank of Pakistan’s Accessibility Framework
2.1 Early Guidance, 2009–2014
SBP has been issuing instructions on banking access for persons with visual impairment since 2009. A more comprehensive framework followed in 2014, addressing account opening, ATM and debit cards, Braille documentation, and internet banking (Shabbir, 2026). This early period established the principle that visually impaired customers were entitled to independent account operation, but left implementation largely to individual banks’ discretion.
2.2 The 2021 Policy for Financial Inclusion of Persons with Disabilities
The clearest and most binding statement of intent followed on June 21, 2021, when SBP’s Banking Conduct and Consumer Protection Department issued Circular No. 05 of 2021, the Policy for Financial Inclusion of Persons with Disabilities. The circular requires each bank’s Board of Directors to approve a comprehensive disability-inclusion policy and strategy document; mandates accessibility audits of branch entrances, washrooms, ATM cabins, counters, and lockers; and requires stationery and account-opening documents in Braille script at controlling offices (State Bank of Pakistan, 2021).
The circular further instructs banks to designate “Model Branches” in every province, scaled to network size, each required to provide ramps, tactile flooring, height-adjusted counters, dedicated token systems and help desks, sign-language interpretation, and staff trained in disability etiquette, with an original implementation deadline of March 31, 2022. Banks operating in the same area are further directed to collaborate so that at least one nearby branch maintains a functioning Talking ATM. Non-compliance is explicitly stated to invoke penal action under the Banking Companies Ordinance, 1962 (State Bank of Pakistan, 2021). This is a materially stronger instrument than general guidance: it names deadlines, assigns board-level accountability, and carries a stated penalty.
2.3 The National Financial Inclusion Strategy, 2024–28
SBP situated disability inclusion within its broader national strategy when it launched the third edition of the National Financial Inclusion Strategy (NFIS) in Karachi on January 12, 2025. One of the strategy’s three core pillars, “Empowering Underserved Segments,” names persons with disabilities alongside women and youth as priority groups, within an overall goal of raising the share of adults with a bank account from roughly 64 percent in 2023 toward 75 percent by 2028 (State Bank of Pakistan, 2025). On paper, in other words, disability-inclusive banking in Pakistan is not a peripheral concern; it is written into binding circulars, board-level accountability structures, and the country’s top-level financial inclusion strategy.
3. The Reality Gap: Evidence from the Field
3.1 Physical Access: ATMs and Branches
A survey of 120 blind and low-vision banking users across Pakistan found that only 17 percent could operate an ATM without assistance, and that most of that minority retained partial rather than complete vision (Shabbir, 2026). For the remaining eight or nine in ten, withdrawing cash requires locating a third party and disclosing a PIN to them. The same survey found that 58 percent of respondents were denied accessible banking services the first time they requested them at a branch; 45 percent had to escalate to senior bank officials to receive accommodations they were already formally entitled to; and 34 percent pursued the matter as far as SBP’s own complaint mechanism (Shabbir, 2026). A qualitative study of banking access in Punjab similarly found that talking ATMs remained unavailable or inaccessible across most cities in the province, notwithstanding SBP’s standing instructions on the matter (Gender and Education Review Journal, 2023).
3.2 Digital Access: Mobile and Internet Banking
Digital channels compound rather than resolve the physical-access gap. More than half of surveyed respondents encountered unlabelled buttons in banking apps, meaning a screen reader could announce only “button,” or a raw code string, with no indication of function. More than 53 percent identified login and authentication procedures, principally visual CAPTCHA, as a hard barrier to independent use. Accessibility also proved unstable over time: one respondent described a beneficiary-selection feature that stopped working with his screen reader after a routine software update, forcing him to disable the reader and locate controls by guesswork; another described watching previously accessible apps degrade as graphics-heavy redesigns replaced simpler, text-based layouts. Only about one quarter of respondents rated their bank’s mobile application as fully accessible (Shabbir, 2026).
3.3 The Human Cost: Dependency, Privacy, and Exploitation
The consequence of this gap is not merely inconvenience; it is a structural loss of financial privacy. Sardar Ahmed Pirzada, described as Pakistan’s first blind journalist and a banking customer for nearly four decades, has compared the experience of being compelled to disclose his PIN to a stranger to “standing naked in front of someone else” (Shabbir, 2026). Reporting on the same research describes account holders, identified by pseudonym, for whom assistance became leverage: one helper began positioning himself as a permanent intermediary for future withdrawals after learning a customer’s balance and routine; another suggested routing a customer’s payments through his own account after helping him read a transaction notice (Shabbir, 2026). These are not presented as isolated instances of bad conduct so much as the predictable output of a system that manufactures dependency by design.
4. Comparative Perspectives: How India Has Approached the Same Problem
Pakistan is not being asked to solve an unprecedented technical problem. India’s central bank, the Reserve Bank of India, issued its own circular on accessible ATMs in 2009, the same year as SBP’s earliest guidance, and several public and private banks have since built substantially on it. Union Bank of India operates what it describes as the country’s first Talking ATM network, delivering voice-guided instructions through a standard headphone jack, paired with the Union Sparsh Braille debit card, which uses a rounded notch opposite the chip and raised Braille markings so that a cardholder can identify and correctly orient the card by touch alone, with account details embossed and positioned for independent reading (Union Bank of India, n.d.). Punjab National Bank and Bank of Baroda have since introduced comparable notched, Braille-marked cards of their own.
An industry retrospective published roughly five years after the RBI’s original circular counted several thousand bilingual, voice-guided ATMs deployed between a handful of major banks, while cautioning that some institutions satisfied only the letter of the requirement, for instance by applying a Braille sticker or a bare “welcome” message rather than genuine audio navigation (XRCVC, n.d.). A more recent account similarly finds meaningful but uneven progress: several major banks now offer talking ATMs and Braille-enabled services, but availability remains inconsistent and far from universal (American India Foundation, 2024).
The comparison is instructive in two directions. First, it demonstrates that the core hardware Pakistan lacks at scale, an ATM that speaks through a headphone jack and a debit card identifiable by touch, is neither exotic nor expensive; it is a solved design problem already deployed next door. Second, it demonstrates that a circular alone does not guarantee substantive accessibility. India’s experience suggests that independent verification and audit, not merely the existence of a rule, is what separates a working Talking ATM from a Braille sticker applied to satisfy an inspection.
5. Recommendations
5.1 For Banks
Publish, per branch, which locations have a genuinely functioning Talking ATM and Braille-capable documentation, rather than leaving customers to discover this through trial and error. Adopt a notched, Braille-marked debit card of the kind already deployed at scale in India. Treat labelling of every interactive element in a mobile banking application as a mandatory pre-release quality assurance step, since an unlabelled button is a design defect rather than a minor omission. Replace visual CAPTCHA with an accessible alternative, such as an audio challenge, at every login and transaction-confirmation screen.
5.2 For the State Bank of Pakistan
Treat the implementation deadlines within Circular No. 05 of 2021 as enforcement dates rather than aspirational targets, and publish bank-by-bank audit results in the manner already used for other prudential requirements. Require independent testing of any accessibility feature a bank reports as available, rather than accepting self-certification, given how easily a Braille sticker can be mistaken for functional access. Extend the existing complaint mechanism into a public reporting dashboard, so that the proportion of customers needing to escalate becomes a visible measure of implementation rather than an internal statistic.
5.3 For Disability Advocates and Civil Society
Press for accessible authentication and interface design to be specified in SBP’s technical standards directly, rather than left to individual banks’ discretion. Continue documenting lived experience with the specificity evident in the research this brief draws upon, since detailed, sourced testimony of denied service is what has moved this issue as far as it has already travelled.
6. Conclusion: Independence, Not Charity
The distance between Pakistan’s disability-banking regulations and a blind customer’s ordinary Tuesday afternoon is not primarily a resourcing problem. A talking ATM runs on a standard headphone jack. A notched card is a manufacturing choice. A labelled button is a line of code. What is absent is not technology but the treatment of accessibility as a standing operational obligation rather than a project considered complete once a circular is signed. Until that changes, customers such as Salman Khalid will continue making the long trip across Lahore to the one machine that allows them to bank as everyone else already does: alone, and on their own terms. That is not a request for charity. It is what a bank account was always meant to provide.
A Note on Sources and Methodology
The survey statistics in Section 3 are drawn from a 120-respondent study of blind and low-vision banking users in Pakistan, cited and reported by Shabbir (2026) with a link to the underlying paper on SSRN (abstract ID 6645999). That primary paper could not be independently retrieved at the time of writing owing to a server access error, and its authorship and full methodology are accordingly reported here at one remove, through Shabbir’s secondary account, rather than verified directly. Readers intending to cite these figures in a more formal setting should attempt to access the original SSRN paper directly to confirm sample composition and survey methodology before publication.
References
American India Foundation. (2024). Banking barriers: The struggle for accessibility in India’s financial institutions. https://aif.org/banking-barriers-the-struggle-for-accessibility-in-indias-financial-institutions/
Gender and Education Review Journal. (2023). Exploring the banking support system available for visually impaired individuals in the local banks: A qualitative study. https://www.gerjournal.com/article/exploring-the-banking-support-system-available-for-visually-impaired-individuals-in-the-local-banks-a-qualitative-study
Shabbir, M. (2026, June 18). The digital interface gap. Stratheia. https://stratheia.com/the-digital-interface-gap/
State Bank of Pakistan. (2021, June 21). Policy for financial inclusion of persons with disabilities (PWDs) (BC&CPD Circular No. 05 of 2021). https://www.sbp.org.pk/cpd/2021/C5.htm
State Bank of Pakistan. (2025, January 12). SBP unveils 3rd edition of National Financial Inclusion Strategy [Press release]. As reported in Pkrevenue.com. https://pkrevenue.com/sbp-unveils-3rd-edition-of-national-financial-inclusion-strategy/
Union Bank of India. (n.d.). Accessible banking services. Retrieved July 2026, from https://www.unionbankofindia.bank.in/en/common/accessible-banking
XRCVC. (n.d.). RBI circular on accessible ATMs … 5 years on: A retrospect and prospect. https://www.xrcvc.org/docs/rbi-circular-on-accessible-atms-5-years-on-a-retrospect-and-prospect.pdf