A woman who is blind using a self-service kiosk at a grocery store

Retail and information kiosks and bank ATMs must be accessible too

All the same drivers—ethical, legal, and commercial—apply to self-service machines

Think about where you’ve been over the last few weeks, or the last time you were in an airport. As you replay these journeys in your mind, note the number of self-service kiosks you encountered. One for depositing checks or withdrawing cash, another for purchasing tickets to a show or checking out at the grocery store, one more for finding your way at a shopping mall, and maybe several for ordering and paying for your meals. If you flew, you most likely interacted with the airline kiosk for checking in and securing your boarding pass.

Whether serving necessity or convenience—or both—interactive kiosks are now a major slice of how we experience independent living: extensions of our personal devices in public places, standing by to help us complete some transaction.

People without disabilities happily use interactive kiosks for important activities—as long as the kiosk experience is easy, fast, intuitive, and convenient. And people with disabilities—more than one-fourth of U.S. adults (2016 data) and 15 percent of the global population—confidently use kiosks too, as long as they are built to be accessible, which is too often not the case.

This state has to change, and companies that use kiosks to interact with customers need to understand accessibility is not only ethical and inclusive—it’s a business and a legal issue. Excluding the world’s largest minority can make your organization vulnerable to lawsuits and complaints, and you’re potentially blocking a large percentage of your customers from using your service.

The global interactive kiosk market size was valued at $27.12 billion USD in 2021 and is forecasted to more than double over the next eight years, according to Straits Research. The ATM kiosk segment is expected to dominate the market in the US with $16 billion in revenue, followed by retail. Familiar categories include quick-service restaurants, ticketing, bill-pay, gaming, hospitality, and photos.

Kiosks represent an enormous opportunity for customers and owners/operators alike. With opportunity comes challenges, one of which is ensuring that kiosks are accessible. This post will examine what makes this platform unique and how to understand existing regulations as well as best practices for owners to meet the needs of all people who encounter the device.

Kiosk: A platform all its own

What differentiates a kiosk? A kiosk requires a simple user interface that can be used without training or documentation. They are designed for unattended operations by customers to conduct a transaction (though employee assistance may also be offered).

Kiosk interfaces can be coded using familiar operating systems—Windows, macOS, Android, iOS, and Linux. The industry has many specialty vendors supplying custom tech stacks. So it should come as no surprise that there is no one self-service solution that might simplify achieving accessibility.

One defining aspect of free-standing kiosks is that they prohibit the user from attaching assistive technologies. The public location mandates that a user cannot install their preferred screen reader or screen enlargement software, nor bring a keyboard or pointing device. This is known as “self-contained,” or closed functionality. This limitation changes how accessibility is managed.

How people with disabilities experience your kiosk

When people who cannot see or interact with touchscreen displays are left out of the kiosk user experience, they are blocked from the service.

What comes to mind when discussing kiosk accommodations is usually the need for wheelchair access. Is the kiosk located at the top of stairs with no ramp? Are the controls within reach? Can the screen be seen?

While ensuring that the physical standards for clearance and maneuvering are met is essential, what is often overlooked is that the digital content must also adhere to the principles of inclusive design. A kiosk or ATM owner is responsible for providing accessibility for both the hardware and software.

Two foundational accessibility solutions that help people with no or low vision:

  • The option to insert a cabled earphone or earbuds into the mini jack to activate a speech engine. Some providers call this accessibility mode.
  • A tactile physical keypad that allows people with no or low vision to navigate and activate controls. A common product uses a four-way directional control with a center action button.

Blending guidelines to build a recipe

Kiosk and ATM vendors, working with accessibility specialists, need to evaluate the usability of their products. Deque accessibility experts understand the uniqueness of the platform—and what it shares in common with better-studied platforms like the web—to create a blended set of guidelines.

The Web Content Accessibility Guidelines (WCAG) are not focused on kiosks but include many relevant provisions. The W3C Web Accessibility Initiative (WAI) had ATMs and other closed systems in mind when documenting non-web content (Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies). And a few industry segments have regulations in place that determine which standards to follow.

Determining which standards apply to kiosks

Unlike web accessibility, there are no universal kiosk accessibility guidelines that provide the path to conformance. Knowing this, let’s take a look at five crucial standards and how each contributes to a recipe of combined checkpoints.

For specific industries, we have these regulations as starting points:

  • Americans With Disabilities Act (ADA) Section 707 for Automatic Teller Machines and Fare Machines
  • Air Carrier Access Act (ACAA) for airport terminal machines

And for retail, informational, point-of-sale (POS) machines, or other non-ATM, non-airline kiosks, we consult:

  • Revised Section 508 of the Rehabilitation Act
  • European Standard EN 301 549
  • Web Content Accessibility Guidelines (WCAG)

Since March 2012, bank ATMs in the U.S. are required to comply with the 2010 ADA Standards for Accessible Design, from the U.S. Department of Justice, specifically Section 707, Automatic Teller Machines and Fare Machines, which are not applicable to other types of self-service machines.

Section 707 defines requirements from operable parts to privacy to speech output and tactile input keys as well as braille instructions, and others such as the physical spacing that allows people with wheelchairs to approach and access the content. If you own ATMs, this is where we will spend our time.

The 2013 U.S. Air Carrier Access Act (ACAA) outlines accessibility requirements for automated airport kiosks. Checkpoints for content specify character size, color contrast, masking characters for security, and speech output, among others.

The regulations require that 25 percent of kiosks installed on or after December 12, 2016, be accessible to people with disabilities and that 25 percent of all kiosks be accessible by December 12, 2022. This escalation in responsibility means more travelers should benefit this year.

In 1998, Congress amended the Rehabilitation Act of 1973 to require federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. Section 508 says all public-facing electronic content must be accessible. It cites self-service machines and information kiosks as examples of information and communication technology (ICT) with closed functionality.

If the content is not web-based, Section 508 says it must conform to all WCAG 2.0 A & AA success criteria, with a few exceptions. Chapter 2 Scoping Requirements lays out where non-web content is exempt. Section 508 gets more precise on kiosks than WCAG does, including technical criteria for the hardware. As a procurement law, Section 508 is enforced through consumers filing formal complaints.

To survive in a competitive global market, US kiosk manufacturers and owners/operators must address export markets. The essential international standard to become familiar with is EN 301 549, a procurement guideline similar to 508 called “Accessibility requirements for ICT products and services in Europe.”

Adopted in European Union member states plus Australia in 2016, this standard refers to kiosks as ICT with closed functionality and expects similar conformance results as the other standards. This standard aligns with WCAG 2.1, whereas Section 508 stops at 2.0.

The Web Content Accessibility Guidelines (WCAG) provide guidance for building web pages, with the expectation that the device allows the user to bring assistive technologies on board. A kiosk deployment may use a web browser and HTML, but it will be pared back to essential transactional content only and probably relies on a touchscreen and keypad combination. Certain WCAG guidelines are not written for closed functionality, but others can inform and aid the development of built-in accessible alternatives.

One example of a WCAG success criterion that can be leveraged for kiosk interfaces is 3.3.4 Error Prevention (Legal, Financial, Data): If the user can change or delete legal, financial, student exam responses, or unrecoverable/unintentionally modified or deleted data, the changes/deletions must be reversible, verified, or confirmed. It’s a critical reality check: If the user is getting ready to submit a form or initiate an action that has real consequences to them (such as financial or legal commitments), then they are given a chance to review and change or cancel the transaction.

Your kiosk or ATM accessibility journey

As an interactive kiosk owner, your software may already be built and therefore need an accessibility audit to determine its accessibility. If you are in the design phase or just now building your software and need guidance, Deque has specialized kiosk accessibility coaches that can help you incorporate accessibility at every step.

Wherever you are in your journey, you will gain a strategy for removing or avoiding barriers. At Deque, we defined the industry’s leading methodology that applies each of the above standards to support your specific platform.

Deque methodology relies on a phased and pragmatic approach that enables testing to occur as accessibility measures are implemented, making the path to accessibility manageable. The first phase is a visual test of screens using a remote emulator. The second phase examines the physical keypad or keyboard to ensure navigation order, visible focus states, and most importantly, that all functionality can be performed without using the touchscreen interface. The third phase tests the speech output that takes the place of traditional screen reader software and may include scriptwriting. Functional usability testing with people with disabilities is the final recommended phase to validate that everything works in the real world as you designed it to.

If a kiosk assessment is driven by a complaint or a lawsuit, the standard to which you must test may be referenced in the legal brief. Be sure to review this document with your accessibility consultant before landing on your specific checkpoints to avoid wasting time, effort, and money on irrelevant fixes.

Rulemaking for self-service machines is coming

A proposed legal update for interactive kiosks in the U.S. appears to be on the horizon. On Sept. 22, the U.S. Access Board published a proposed rule that could provide supplemental ADA guidelines for self-service equipment to be used in public accommodations. The DOJ will be solely responsible for determining when the requirements will become effective.

The board seeks comments (now through Nov. 21, 2022) from users and manufacturers of self-service kiosks on their experiences in using or designing accessible machines and the benefits and costs associated with the proposed requirements. When the results are eventually codified, it may lead to less ambiguity in achieving accessibility with kiosks. This is good news for customers and reinforces the need to build accessible kiosks and remediate existing ones now.

Postponing accessibility debt will only increase exposure to legal risk as well as take more away from your bottom line.

Interested in tracking kiosk legal cases and regulatory developments?

Follow Seyfarth’s ADA Title III coverage and articles from attorney Lainey Feingold.

Good news: All kiosks can be made accessible

From checking in at the doctor’s office to checking bags at the airport, customers want to complete their transactions in a few simple steps—without the need for assistance. On a strategic level, kiosks provide banks and retailers with a superb tool for testing core functions and new tech with their customers. On a practical level, inaccessible kiosks create even larger barriers between people with disabilities and our aging population and their need to participate fully in our digital world.

As we say often in the accessibility industry, fixing problems never works as well as avoiding them to begin with. Commit to assessing the needs of all users early and throughout the design, development, and testing lifecycle. Kiosks and ATMs can be made fully accessible and meet regulatory requirements. It’s good for humans and good for business. Contact us to learn how we can partner to create self-service success stories.

Photo of Phil Daquila

About Phil Daquila

Phil Daquila is a subject matter expert coaching web development teams in all roles and consulting on how to meet the needs of all users. After a few decades producing magazines, books, and documentary videos, Phil found a new passion in digital accessibility in 2016. At UNC-Chapel Hill, he trained site owners in practicing inclusive design and coding. At Deque since 2019, Phil is a Certified Professional in Web Accessibility with IAAP and the kiosk lead for the standards and methodology team. Phil hosts the Deque Coaching Book Club.
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