The European Accessibility Act (EAA) covers self-service terminals as a regulated product category, which means ATMs, ticketing machines, check-in kiosks, and payment terminals placed on the EU market must meet accessibility requirements. The rules went into effect on June 28, 2025. Manufacturers, importers, and distributors are responsible for confirming that hardware, software, and supporting services meet the functional requirements set out in Annex I of the directive. EN 301 549 is the harmonized standard most operators map to when documenting conformance.
| Item | Detail |
|---|---|
| Effective date | June 28, 2025 |
| Covered terminals | ATMs, ticketing machines, check-in kiosks, payment terminals, interactive self-service machines tied to in-scope services |
| Who is responsible | Manufacturers, importers, distributors, and the service operators that deploy the terminals |
| Reference standard | EN 301 549, mapped to Annex I functional requirements |
| Documentation | EU Declaration of Conformity, CE marking, technical file, accessibility information for users |
Which Terminals Fall Under the EAA?
The directive lists self-service terminals as in-scope when they are used to deliver a covered service. That includes payment terminals and any self-service terminal connected to banking services, e-commerce, passenger transport, or electronic communications.
Common examples include ATMs operated by banks and independent ATM deployers, ticketing machines at train stations, metro systems, and bus terminals, check-in kiosks at airports, point-of-sale payment terminals in retail and hospitality, and information kiosks tied to a covered service.
Vending machines that sell physical products outside of a covered service are generally not in scope. The connection to a regulated service is what pulls a terminal under the EAA umbrella.
What Do the Functional Requirements Cover?
Annex I of the EAA sets functional requirements rather than prescriptive technical specifications. For self-service terminals, this means designing for users with vision, hearing, speech, cognitive, and physical disabilities.
Core areas include perceivable output through more than one sensory channel (visual plus audio, for instance), text-to-speech support with private listening through a headphone jack, adjustable text size, contrast, and timing, tactile keys and a physical keypad where input is required, reachable controls at heights and positions usable from a seated position, clear instructions and predictable interaction patterns, avoidance of flashing content that could trigger seizures, and biometric methods that offer an alternative for users who cannot use them.
Operators typically map these requirements to EN 301 549, which translates the functional outcomes into testable criteria across hardware and software.
How Does EN 301 549 Apply to Terminals?
EN 301 549 is the European harmonized standard for ICT accessibility. It covers web, software, documents, and hardware, including self-service terminals. Chapter 8 addresses hardware specifically, and several chapters address the software interface running on the terminal.
For a payment terminal or ticketing kiosk, evaluation work usually spans hardware requirements in Chapter 8 (operable parts, keys, controls, reach), software requirements in Chapter 11 including WCAG 2.1 AA criteria applied to the on-screen interface, and documentation and support service requirements in Chapters 12 and later.
Mapping to EN 301 549 gives manufacturers a defensible path to demonstrate that their terminal meets the EAA’s functional requirements.
Who Is Responsible for Conformance?
The EAA assigns duties across the supply chain. Manufacturers carry the heaviest load: they must design the terminal to meet the requirements, prepare technical documentation, conduct conformity assessment, draw up the EU Declaration of Conformity, and affix the CE marking.
Importers verify that the manufacturer has done this work before placing a terminal on the EU market. Distributors check that the CE marking and required documentation are present.
Service operators, such as banks deploying ATMs or transport authorities running ticketing networks, are responsible for the service itself being accessible. That responsibility extends to the terminals they choose and how they configure them.
What Documentation Is Required?
A conforming terminal needs a technical file that demonstrates how the product meets each requirement, an EU Declaration of Conformity signed by the manufacturer, CE marking visible on the product, and accessibility information made available to users and operators.
Service providers using the terminals must also publish accessibility information about the service, including how the terminal supports users with disabilities and which features are available.
Are There Exceptions?
The directive allows two narrow exceptions. The first is disproportionate burden, which lets an economic operator argue that meeting a specific requirement would impose an unreasonable cost relative to the benefit. The second is fundamental alteration, where meeting a requirement would change the basic nature of the product.
Both exceptions require documented justification, and microenterprises offering services have lighter obligations. Neither exception removes the overall obligation to design accessibility into the product wherever feasible.
How Should Operators Approach This Now?
The rules are already in force. Operators with deployed fleets are working through inventory reviews, conformance evaluations against EN 301 549, and procurement updates that require accessibility evidence from vendors.
A practical path starts with inventorying every terminal model in the fleet and the service it supports, then requesting EU Declarations of Conformity and accessibility documentation from manufacturers. From there, operators evaluate any gap between the current state and EN 301 549 requirements, plan remediation, replacement, or firmware updates with realistic timelines, and update procurement criteria so future purchases include accessibility evidence.
Accessible.org works with companies preparing for EAA obligations across digital products and connected hardware interfaces.
FAQ
Do existing terminals need to be replaced immediately?
The directive includes a transition provision for service providers using self-service terminals that were already in use before June 28, 2025. Those terminals can continue to be used for their economically useful life, up to a maximum of 20 years from when they were put into use. New terminals placed on the market after the effective date must conform.
Does the EAA apply to vending machines?
Standalone vending machines selling physical goods outside a covered service generally fall outside the EAA. If a vending machine is integrated into a covered service, such as a transport ticketing system, it can be drawn into scope.
How does the EAA interact with national laws?
Each EU member state has transposed the directive into national law, which means specific enforcement, penalties, and reporting can vary. The core requirements are consistent across the EU, but operators should verify national specifics for every market they serve.
What is the relationship between WCAG and self-service terminals?
WCAG 2.1 AA applies to the software interface running on the terminal through EN 301 549 Chapter 11. The hardware requirements come from Chapter 8 and other sections. A complete evaluation addresses both layers.
Self-service terminals sit at an intersection of hardware engineering, software design, and service operations, which makes EAA conformance a coordinated effort across teams and vendors.
Contact Accessible.org to discuss EAA readiness for your products and services: accessible.org/contact.
