Master Accessibility Check-List
Designing self-service kiosks and ICT devices for international markets requires meeting both US (ADA Title II/III, Section 508) and EU (EAA, ETSI EN 301 549) accessibility rules. This harmonized checklist outlines the physical, audio, software, and documentation requirements needed to comply with ADA and EAA simultaneously.
If a manufacturer implements only this list, the product conforms to ADA, Section 508, ACAA/DOT, EAA/EN 301 549 and WCAG 2.2 AA simultaneously. In the US, there are regional clarifications (Braille labels in California for example).
We will add in Korea, India and perhaps China to round things out. This is an analysis of all our source docs. Nothing is lawyer-proof.
Hardware
• Operable parts between 380 mm and 1200 mm; clear floor space 760 × 1220 mm; knee and toe clearance per ADA 306; no protruding objects per ADA 307.
• Tactilely discernible physical controls for all functions available on the touchscreen.
• Numeric keypad in 12-key telephone format, tactile home key on 5, 16 or 19 mm pitch; function keys in a right-hand column at 3× spacing with tactile idents (X, <, ?, O).
• Tactile idents minimum 5 × 5 mm, preferred 10 × 10 mm; lines ~1 mm wide raised ≥0.5 mm; radiused edges.
• Keytops raised ≥0.5 mm; ≥3:1 contrast on key boundaries; sans-serif keytop characters; audible or tactile keypress confirmation.
• Actuation force ≤3.0 N; one-handed operation; no tight grasping, pinching or twisting.
• 3.5 mm private-listening jack, tactilely locatable, with a tactile or illuminated locator symbol.
• International Symbol of Accessibility on the front of the device; voice-command symbol where applicable.
• Screen visible from a point 40 in (1015 mm) above the floor; sunlight-readable specification documented for outdoor units.
Audio
• Speech output enabled on every closed-functionality terminal with a display.
• Repeating welcome message on headset connection, with volume and start instructions.
• User control: pause, dwell, repeat, go back, and abandon (3-second press-and-hold on enter/select).
• Incremental volume to ≥65 dB SPL; ≥20 dB over ambient selectable where ambient >45 dB SPL; automatic reset to default after every use.
• Speech coordinated with on-screen content; transactional outputs spoken sufficiently to complete and verify; masked characters spoken.
• Advertising content exempt from speech unless transactionally relevant.
Software and content
• WCAG 2.2 Level AA across the full transaction path, with a published per-criterion applicability profile.
• Built-in screen reading, magnification and audio navigation for closed-functionality units.
• Timeouts announced in all available modalities, extendable, non-destructive.
• Accessible authentication with no cognitive-function-test dependency.
• Error identification, suggestion and prevention on every input.
• No reliance on colour alone; no flashing above the three-flash threshold.
Governance and evidence
• VPAT INT edition covering Section 508, EN 301 549 and WCAG 2.2, refreshed at each material release.
• EU Declaration of Conformity and CE marking for EAA-scoped products.
• ACAA density and certification records where aviation applies.
• Accessible documentation and support materials conforming to WCAG 2.2 AA.
• Task-completion testing with disabled participants, retained as evidence..
• Non-biometric alternative documented for every biometric flow.
Frequently Asked Questions
1. Does this checklist make a kiosk legally compliant everywhere?
No. This is a harmonized engineering and procurement checklist—not a legal opinion or a substitute for jurisdiction-specific review. It is designed to cover the major overlapping accessibility expectations for U.S. ADA/Section 508-style deployments and EU EAA/EN 301 549 ICT requirements, but final obligations can depend on the product, purchaser, installation location, service category, and local enforcement rules. The EU EAA has applied to covered products and consumer services since 28 June 2025, with special transition treatment for certain existing self-service terminals.accessible+1
2. Why does the checklist require speech output if EN 301 549 does not always require it?
The list takes the more conservative U.S.-plus-EU approach. U.S. Section 508 requirements for closed-functionality ICT with a display generally require speech output for full and independent use by people with vision impairments. The U.S. Access Board specifically identifies this as a difference from EN 301 549’s closed-functionality provisions, which frame several speech requirements as applying where speech output is provided. Including speech, private listening, tactile activation, repeat, pause, and volume controls helps create a design that works across both regimes.section508+1
3. Is WCAG 2.2 AA alone enough for a physical kiosk?
No. WCAG is essential for software and digital content, but it does not by itself address many kiosk-specific barriers: reach ranges, clear floor space, knee/toe clearance, tactilely discernible hardware controls, private listening, headset-jack location, physical key layout, actuation force, or installation conditions. A conforming self-service deployment needs the combination of accessible software, accessible hardware, and an accessible installed environment.
4. Do all kiosks need a physical keypad and 3.5 mm headphone jack?
Not necessarily in every deployment, but a touchscreen-only design creates substantial accessibility risk for closed-function systems. A physical, tactilely discernible input method is the most dependable way to ensure independent access for users who cannot effectively use a flat touchscreen. Likewise, a standard private-listening connection is a practical, widely supported way to make speech output usable in public settings. Any alternative should be validated against the applicable standard, product category, user needs, security model, and procurement specification—not assumed equivalent because it is newer or wireless.
5. What evidence should a manufacturer or operator retain?
Retain evidence throughout the product lifecycle, not just at launch. At minimum, keep the current VPAT INT or equivalent accessibility conformance report; WCAG/EN 301 549 applicability and test results; hardware drawings and measurements; accessibility test scripts; defect and remediation records; accessible user documentation; task-completion testing involving disabled participants; and release-by-release accessibility change records. For EU products in scope, maintain the technical documentation and Declaration of Conformity that support CE-marking obligations. Evidence should be refreshed whenever hardware, firmware, operating system, transaction flow, payment flow, or user interface changes materially.
Section 508 and EAA Compared
This always gets done but we will do it again.
Where the standards genuinely overlap
The overlap is broad enough that a single hardware platform is realistic:
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Dimensional envelope. Unobstructed 1220/380 mm, obstructed forward 1220/1120 mm, obstructed side 1170 mm with a 865 mm obstruction ceiling, 635 mm maximum forward reach, and 760 mm minimum clearance width appear in both regimes with the same numbers (Cornell LII, ETSI).
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Screen sightline. 1015 mm / 40 inches in Section 508 408.2, EN 8.3.5 and ADA 707.7.1.
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Audio amplification and reset. 65 dB(A) with an automatic post-transaction reset in both 402.3.2 and EN 5.1.3.13.
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Force ceiling. 22.2 N in 407.6 and EN 8.4.2.2.
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Speech for transaction verification. 402.2.2 and EN 5.1.3.16 ask the same question in nearly the same words.
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Tactile 5 key and media orientation. 407.3.3 / 407.7 versus EN 8.4.1 / 8.4.3.
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Non-visual mode as a first principle. 302.1 “at least one mode of operation that does not require user vision” (Cornell LII) versus Annex I 2(a)’s multi-sensory duty with “alternatives to vision, auditory, speech and tactile elements” (EAA Annex I) and EN 5.1.3.1.
Where they diverge, and which way
Accessibility Standards, Regulations and Source Documents
The following standards, regulations and industry guidance documents provide the primary reference base for kiosk and self-service accessibility requirements in the United States, Europe and international markets.
Kiosk Manufacturer Association (KMA)
- Kiosk Manufacturer Association, ADA and Accessibility Report 2019, Parts 1–5
(Master Overview, Mandated Requirements, Proposed Code of Practice, Tactility/Voice Recognition/Speech Command, and Addendum), 20 October 2019.
Historical source documents supplied by KMA.
See also:
KMA Voice, Tactility and Accessibility Guidance
. - Kiosk Manufacturer Association, Global Accessibility Harmonization Framework v1.0,
draft for review.
This document should be treated as industry guidance rather than a published regulation or consensus standard.
United States Access Board
- U.S. Access Board, Revised Section 508 Standards and Section 255 Guidelines.
Information and Communication Technology Standards and Guidelines
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The standards establish accessibility requirements for federal information and communication technology, including provisions affecting closed-functionality ICT. - U.S. Access Board, Final Rule Preamble for the Revised 508 Standards and 255 Guidelines.
Final Rule Preamble
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The preamble discusses differences between the U.S. requirements and EN 301 549, including treatment of closed-functionality ICT and speech output. - U.S. Access Board, Americans With Disabilities Act Accessibility Guidelines; Self-Service Transaction Machines and Self-Service Kiosks, Advance Notice of Proposed Rulemaking,
87 FR 57662, 21 September 2022.
Federal Register, 87 FR 57662
. - U.S. Access Board, Information and Communication Technology (ICT) Final Standards and Guidelines,
82 FR 5790, 18 January 2017.
Federal Register Final Rule
.
U.S. Department of Transportation
- U.S. Department of Transportation, Nondiscrimination on the Basis of Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks.
DOT Final Rule
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See also
14 CFR § 382.57
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The rule requires at least 25% of automated airport kiosks in each location to meet applicable accessibility requirements.
DOT subsequently clarified that references in the published regulatory text to a 12 December 2022 compliance date should read 12 December 2023.
U.S. Department of Justice
- U.S. Department of Justice, Spring 2025 Unified Regulatory Agenda,
90 FR 45532, 22 September 2025.
Federal Register, 90 FR 45532
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The agenda includes ADA Title II and Title III regulatory activity, Section 610 reviews and accessibility-related rulemaking.
VPAT and Accessibility Conformance Reporting
- Information Technology Industry Council (ITI), Voluntary Product Accessibility Template (VPAT®).
Official VPAT Resources
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For current harmonized accessibility reporting, use the latest available revision and, where appropriate, the International (INT) Edition, which supports reporting against WCAG, Revised Section 508 and EN 301 549.
European Union
- Directive (EU) 2019/882 of the European Parliament and of the Council — European Accessibility Act (EAA).
Directive (EU) 2019/882
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The Directive establishes accessibility requirements for specified products and services, including certain self-service terminals. - European Union of the Deaf, European Accessibility Act Toolkit for Transposition.
EAA Transposition Toolkit
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The toolkit provides a useful summary of EAA scope, national transposition and transitional periods.
ETSI EN 301 549
- ETSI EN 301 549, Accessibility requirements for ICT products and services.
ETSI EN 301 549 Document Repository
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EN 301 549 is the principal European ICT accessibility standard and is widely used in conjunction with WCAG and European accessibility legislation.