The EAA self-service terminals rules reach well beyond websites. Since 28 June 2025, the European Accessibility Act has applied to payment terminals, ATMs, ticketing machines, check-in machines and interactive information kiosks placed on the EU market (Directive (EU) 2019/882, Article 2(1)(b)). The hardware and the software running on it are both in scope. Terminals built into vehicles, aircraft, ships or rolling stock are excluded.
On top of the general product requirements, Annex I adds seven duties that apply only to terminals. A terminal must offer text-to-speech, accept a personal headset, warn about time limits through more than one sense and let the user extend them, have adequate contrast and tactile keys where it has keys, let someone turn on an accessibility feature without already needing it, and work with hearing aids and telecoils when it uses audio (Annex I, Section I, point 2(o)(i)).
The manufacturer has to build a conforming product, and the bank, airline or retailer running the terminal has to provide an accessible service with it. Older terminals may get a long transition, depending on national law.
Which self-service terminals does the EAA cover?
Article 2(1)(b) of the EAA lists two groups. The first is payment terminals, with no further condition. The second is terminals "dedicated to the provision of services covered by this Directive", namely:
- automated teller machines;
- ticketing machines;
- check-in machines;
- interactive self-service terminals providing information, except those installed as integrated parts of vehicles, aircraft, ships or rolling stock.
Recital 26 adds concrete examples: travel ticket dispensers, bank office queuing ticket machines and "interactive information screens", and it confirms that coverage includes "both their hardware and software" (Recital 26).
The "dedicated to" condition does real work. An ATM serves consumer banking and a check-in kiosk serves passenger transport, both in-scope services. A self-checkout till is a device whose main purpose is taking card payments at a physical point of sale, which is how Article 3(29) defines a payment terminal. A wayfinding screen in an office lobby, tied to no covered service, is a weaker case; get legal advice before relying on either reading.
Transport repeats the point from the service side: Article 2(2)(c)(v) covers terminals used for air, bus, rail and waterborne passenger services. Even urban and regional transport, spared most service rules, must make its terminals meet Annex I, Section I (Annex I, Section IV(d)).
Who is responsible: the manufacturer or the operator?
Both, for different things.
The manufacturer places the terminal on the market as a product. It must design it to meet Annex I, draw up technical documentation, run the conformity assessment, issue an EU declaration of conformity and affix the CE marking (Article 7). It keeps that documentation for five years.
The service provider (the bank running ATMs, the rail operator with ticket machines) must "design and provide services in accordance with the accessibility requirements" and publish information on how the service meets them (Article 13). Buying conforming hardware is a large part of that, not all of it. If your team builds the ticket-purchase flow on a vendor's kiosk, that flow is your code and your problem.
What does the EAA require of a self-service terminal?
All of Annex I, Section I applies. That includes information through more than one sensory channel, flexible magnification and contrast, alternatives to colour and to audible signals, no need for fine motor control or great strength, an alternative to biometric identification, and privacy when someone uses an accessibility feature (Annex I, Section I, point 2(a)–(n)).
Point 2(o)(i) then adds the terminal-specific list. Quoted directly, a self-service terminal:
- "shall provide for text-to-speech technology";
- "shall allow for the use of personal headsets";
- "where a timed response is required, shall alert the user via more than one sensory channel";
- "shall give the possibility to extend the time given";
- "shall have an adequate contrast and tactilely discernible keys and controls when keys and controls are available";
- "shall not require an accessibility feature to be activated in order to enable a user who needs the feature to turn it on";
- when it uses audio, "shall be compatible with assistive devices and technologies available at Union level, including hearing technologies such as hearing aids, telecoils, cochlear implants and assistive listening devices".
The sixth item is the easiest one to get wrong. A touchscreen kiosk whose speech mode sits behind an on-screen "Accessibility" button is unusable by the person who needs speech, because they can't see the button. Annex II gives the intended pattern as a non-binding example: visual and tactile, or visual and auditory, information showing where to insert a card, so that both blind and deaf people can use the terminal (Annex II).
How does EN 301 549 turn this into testable checks?
EN 301 549 turns the Act's outcomes into pass/fail tests, and V4.1.1 (published September 2026) maps each of the seven terminal duties to specific clauses in Table ZB.2, rows 15 to 21 (ETSI EN 301 549 V4.1.1, Annex ZB). A caveat first: V4.1.1 isn't yet cited in the Official Journal, so the legal reference remains v3.2.1 (AccessibleEU, September 2026). The clause numbers below are from V4.1.1.
Most kiosks have what the standard calls closed functionality: the user can't install a screen reader or open system settings. Clause 5.1 is written for exactly that case. The clauses that matter most:
| EAA duty (Annex I 2(o)(i)) | EN 301 549 V4.1.1 clause | What you actually test |
|---|---|---|
| Text-to-speech | 5.1.3.1 Auditory output of visual information | Every prompt, error and on-screen choice needed to finish the transaction is spoken |
| Personal headsets | 5.1.3.2 Auditory output delivery | On a public terminal, speech plays through the built-in speaker or a 3.5 mm jack you can find without vision |
| Tactile keys and controls | 5.5 Tactilely discernible operable parts | All functions can be operated without vision using parts you can locate by touch |
| Feature activation | 5.2 Activation of accessibility features; 8.5 Tactile indication of speech mode | The way into speech mode can be found and used by someone who can't see the screen |
| Timing | 5.1.3.1, 9.2.2 / 11.2.2 (timing adjustable) | Timeouts are announced in speech as well as on screen, and the user can extend them |
Two more clauses belong in your test plan. Clause 5.1.3.16 requires that any information on a printed receipt or ticket needed to complete or verify the transaction is also available through speech. Clause 8.4.3 requires that cards and tickets whose orientation matters have a tactilely discernible orientation. On a ticket machine that prints a QR code you have to insert face-up at the gate, that is a real requirement, not a detail.
Clause 8.3 covers physical placement for stationary ICT such as kiosks. In V4.1.1, no part of a display may extend below 800 mm above the floor of the access space (8.3.2), and information needed to operate the terminal sits no higher than 1,600 mm, or 2,000 mm where design constraints make that impossible (8.3.3.1 and 8.3.3.2).
Do terminals installed before June 2025 have to be replaced?
Not necessarily. Article 32(2) lets Member States allow self-service terminals "lawfully used by service providers for the provision of services before 28 June 2025" to stay in use "until the end of their economically useful life, but no longer than 20 years after their entry into use" (Article 32(2)). Recital 101 adds the condition that they are not replaced during that period.
"May provide" means this is a national choice, so check the transposing law in each country where your terminals stand. And the clock runs from the terminal's own entry into use, not from 2025. An ATM installed in 2010 reaches its 20-year limit in 2030.
The disproportionate burden rule also has a terminal-specific angle. Recital 69 says a service provider that can't make every terminal accessible without a disproportionate burden should still assess whether "a limited level of accessibility in all self-service terminals or a limited number of fully accessible self-service terminals" is achievable, and comply to that extent (Recital 69; Article 14). That assessment has to be documented and kept for five years. Our post on the disproportionate burden exemption covers how the assessment works.
What can an automated scan check on a kiosk?
Very little of the hardware, and I'd rather say that plainly. A scanner can't confirm that a headset jack works, that the keypad has a raised dot on the 5, or that speech starts when a blind user touches the screen edge. Those are physical and behavioural checks. You need a person with a headset, ideally a screen-reader user, standing at the machine.
Automation can cover the software layer when the kiosk UI is a web app, often a browser in kiosk mode loading a URL. If you can load that URL on a desktop, a free scan will flag unnamed buttons (WCAG 4.1.2), contrast failures (1.4.3) and missing labels with the failing selectors. The contrast checker helps too, though a sunlit kiosk screen reads worse than any lab monitor. Across the web generally, automated testing finds about 57% of issues by volume, and around a third measured by WCAG success criteria (Deque, 2021). On a kiosk the share is lower, because so many requirements are physical. Full conformance needs human review.
My view: retrofitting speech output and tactile navigation onto a touchscreen-only kiosk costs far more than specifying it up front. If you are buying terminals now, paste Table ZB.2 rows 15 to 21 into the procurement spec and ask the vendor to show you the EU declaration of conformity before you sign.
What should the accessibility statement say about terminals?
Service providers have to explain how their service meets the requirements, in writing and orally, in an accessible format (Article 13(2), Annex V). For terminals, name which machines have speech output and headset jacks, and where they are if only some do. An accessibility statement documents your efforts and known gaps. It isn't a promise that every machine works for everyone. The statement generator gives you a structure for the web and app parts.
Frequently asked questions
Are self-checkout tills covered by the EAA?
Yes, as payment terminals. Article 2(1)(b)(i) covers payment terminals without requiring them to be dedicated to a particular service, so hardware and software placed on the EU market after 28 June 2025 must meet the product requirements.
Do kiosks need a headphone jack under the EAA?
The EAA requires terminals to "allow for the use of personal headsets". EN 301 549 clause 5.1.3.2 accepts either a built-in mechanism, such as a speaker or handset, or a 3.5 mm jack that can be found without vision on a public terminal.
Does a touchscreen-only kiosk comply?
Only if the touchscreen can be operated without vision. EN 301 549 clause 5.5 accepts touchscreen areas next to tactile edges or markings, but every function, including turning on speech, must work for a user who can't see the screen.
Can a web accessibility scanner test a kiosk?
Only the web-based software layer. If the kiosk runs a web app you can load by URL, a scanner can find code defects such as unnamed buttons and low contrast. Speech output, tactile controls, headset support and physical placement need hands-on testing.
Check the software you can reach today
If your kiosk or ticketing flow runs as a web app, start there. Scan the kiosk URL for code-level failures, fix them, and then book a session at the machine itself with a headset and a tester who uses speech output.
Pavel Charkasau, founder, wcagc.com. Last updated 19 October 2026.
Sources
- Directive (EU) 2019/882 (European Accessibility Act), EUR-Lex: scope (Article 2(1)(b), 2(2)(c)(v)); Article 4(2); manufacturer duties (Article 7); service provider duties (Article 13); Article 14; transitional measures (Article 32(2)); Recitals 26, 69 and 101; Annex I, Sections I and IV(d); Annex II; Annex V. Accessed 19 October 2026.
- ETSI EN 301 549 V4.1.1 (2026-09): clauses 5.1.2, 5.1.3.1, 5.1.3.2, 5.1.3.16, 5.2, 5.5, 8.3, 8.4.3, 8.5; Annex ZB, Table ZB.2 rows 15–21. Accessed 19 October 2026.
- The European accessibility standard EN 301 549 has been updated, AccessibleEU: V4.1.1 citation status. Accessed 19 October 2026.
- Automated testing identifies 57% of accessibility issues, Deque: automated coverage by volume and by success criteria. Accessed 19 October 2026.